A man wearing glasses is focused on working on his laptop at a desk.

Firm-Wide Risk Assessment Support

Need support with your Firm-Wide Risk Assessment?

We will draft a new, bespoke FWRA for your Firm, or support you to close the gaps in your existing one.

Why Firms Must Maintain an Up-to-Date FWRA

Under regulation 18, Firm-Wide Risk Assessments (also referred to as Practice-Wide Risk Assessments) are mandatory for firms conducting work within the scope of the MLR2017.

In a nutshell, they need to accurately describe two aspects:

An assessment of the unique money laundering risk profile of the firm.
An assessment of the effectiveness of the firm’s controls to manage the risks.

In the event that your firm receives an AML Inspection from the SRA, an up-to-date FWRA is one of the very first, if not the first document that the SRA will ask to see.

Is Your Firm’s FWRA As Current as It Should Be?

The AML landscape today is almost unrecognisable from the landscape just two years ago.

And so, including under the context of Rules, 2.1a, 2.2, 2.5 and 3.1 of the 2019 SRA Code of Conduct for Firms, your firm’s FWRA needs to be regularly reviewed and updated in reflection not only of the situation at your firm, but also any external changes (including guidance from the SRA).

You FWRA must be driven by risk data

Simply setting out a set of statements/summaries into a template, about the firm’s assessment of the risk, is no longer sufficient.

Instead, an effective, authentic FWRA will show the ‘workings-out’ to support the conclusions reached. This means including metrics in respect of the components of the firm’s risk profile and in respect of the measurement of the application of the controls.

A meaningful, authentic FWRA, that includes relevant metrics and underpinning for its conclusions, is not unlikely to run to over 30 pages, even for a smaller firm.

No Two Firms Have the Same Risk Profile, Ever

As with everything else that we do at PDA, we never use or supply raw templates; they invite trouble because they will not provide an accurate picture of the controls and unique risk profile at your firm.

Moreover, just like us, regulators can spot a raw template from a mile away and might take that as a cue to dig deeper.

How We’ll Help You

Everything that we do at PDA is tailored to each firm.

Option 1: We draft a new FWRA for you, from the ground, up

We will conduct a series of telephone or Teams calls with your AML Officer(s) where we will ask a series of structured questions to ascertain the unique risk profile of your firm and the controls that you have in place.

Then we’ll draft a whole new FWRA for you, that we’ll provide to you as a Word document that is easy for you to maintain in the future.

We often provide this service following SRA Inspections.

Option 2: We conduct a gap analysis of your existing FWRA

This option is provided in case you are not sure whether or not you need to update your existing FWRA.

Having received a copy of your existing FWRA, we examine the contents and provide you with a written report on any gaps, as well as providing suggestions for best practice.

Sometimes, firms take our report away to update their FWRA by themselves. Most often however, they ask us to help them to close the gaps.

Option 3: We help you to fill specific gaps in your FWRA

If your existing FWRA requires only a few adjustments, we’ll use the same approach of a series of calls with you to obtain the information, which we will embed into your existing document.

Pricing

We strive to provide you with unparalleled value through services that are bespoke to your practice.

Our pricing is competitive and transparent. And, it’s tailored according to the scope of the work that that we do for you.

Wherever possible, we conduct work on a fixed fee basis.

Join our free Best Practice Group and save:

Members of our free-to-join Best Practice Group receive a substantial discount on all of our services.

Find out more

Book your free consultation today

Additional AML Support Services

In addition to FWRAs, we also help support you with a range of additional AML related services. Contact us today to request a free initial AML consultation today.