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SRA issues financial penalty for non-compliant FWRA and AML PCPs
11 December 2023

Following an investigation into Angel Wilkins LLP, the SRA issued a financial penalty of £7,900 plus costs after finding that between June 2017 and March 2023 the firm’s firm-wide risk assessment (FWRA) did not address all five key risk areas required under Regulation 18 of the Money Laundering Regulations 2017 in sufficient detail. The firm had an AML policy in place since its inception but the SRA’s desk-based review concluded that this did not cover all of the mandatory requirements of Regulation 19 of the MLRs 2017. The firm has since updated its FWRA in line with requirements and also put compliant PCPs in place. Although there was no harm caused to consumers or third parties and the firm cooperated fully with the SRA, showed remorse and made the required rectifications, the SRA stated that the firm’s conduct showed a disregard for statutory and regulatory obligations and had the potential to case harm, by facilitating dubious transactions that could have led to money laundering and felt that a financial penalty was appropriate to act as a deterrent to others and maintain professional standards.

For further detail, see SRA | Angel Wilkins LLP – 524327 | Solicitors Regulation Authority

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