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Firm anti-money laundering and sanctions data requirements
06 August 2024
What you need to know
We are asking all regulated firms to provide us with information on:
- work they carry out within scope of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- any contact or involvement they have with the sanctions regime and any persons who are designated under it
- submission of suspicious activity reports to the National Crime Agency.
We appreciate that not all firms are involved with one or more of these regimes – in which case, you will be able to submit a nil return. This will help us to keep our information up to date.
The window for firms to complete the form is from 8 August to 23 September 2024.
Why are we collecting this data?
We are required by our own regulator, the Office for Professional Body Anti-Money Laundering Supervision to take a risk-based approach to supervision.
To supervise the legal sector effectively, we need to have accurate data. This allows us to see the distribution of risk across the legal profession, which in turn informs our programme of inspections and our guidance.
Collecting this information allows us to establish where the risks lie and how we can better allocate our resources. Most importantly, this data needs to be up to date and relevant so that our approach can evolve and adapt.
If we decide to publish this data, we will make sure that no one can be identified from any data that we publish or share with others.
Read more about privacy, data and information at the SRA.
If you have any questions, please contact us.
Collecting AML and sanctions data
The questionnaire
To help you prepare, download a specimen version of the questionnaire.
Please note that this is provided for information and guidance only to help you prepare your return – all submissions must be made via our online portal. We will not accept submissions via email or hard copy post. These will only be accepted if reasonable adjustments are agreed and applied.
Completing the questionnaire
The questionnaire must be completed by someone at your firm who holds one or more of the following roles:
- Compliance officer for legal practice
- Authorised signatory
- Money Laundering Compliance Officer
- Money Laundering Reporting Officer.
We understand that firms store and categorise their data in different ways. While we ask you to answer to the best of your knowledge and provide the most precise information possible, we will accept estimates if exact figures are not available.
Questions and answers
Open allWe understand that firms have different ways of storing information and these may not always align with the questions we ask.
In particular, we recognise that trusts and company services may cross several different work areas and departments.
We want you to use your best efforts in answering the questions accurately, as this will improve the quality of our data and our assessment of risk. If this is not possible, though, please give your best estimate.
Yes. The application is wider than matters in scope of the MLR 2017, and we also need to refresh our data about firms which are or are not in scope. You will be asked early in the questionnaire about whether you are in scope of the MLR 2017, and if you answer no, you will not need to answer further questions on that section.
Yes. Among other things, this section helps us see how exposed the profession is to the risk of sanctions and understand how many firms carry out work in this area. If these questions do not apply to you, please reflect this in your answers.
This request is made under Rule 3.3 of our Code of Conduct for Firms:
You respond promptly to the SRA and:
- provide full and accurate explanations, information and documentation in response to any requests or requirements;
- ensure that relevant information which is held by you, or by third parties carrying out functions on your behalf which are critical to the delivery of your legal services, is available for inspection by the SRA.
The Legal Services Act 2007 section 111A also allows us to proactively request information in the performance of our regulatory functions to prevent or detect economic crime.
No, this is a separate exercise which asks different questions. You will still need to submit your usual practising certificate renewal data in October 2024.
No. The online form will not be available in mySRA. Instead, please follow the 'Log in' link that will appear on this page during the data collection period. Enter your mySRA login details to access the form.
If this work area accounts for more than 0% but less than 1% of turnover or open matters, please round this up to 1%.
If it straddles a boundary, for example 50.4%, please round this up to the nearest whole number.
Please aim to provide data for the previous twelve calendar months before you submit the questionnaire or as close as you are able.