Solicitors

AML: staying Best informed

Calum MacLean 07 August 2025

Anti-money laundering (AML) remains a top concern for law firms, as highlighted by Miller’s recent Risk Benchmarking survey.

With new regulations on the horizon, updated LSAG guidance, and the Solicitors Regulation Authority (SRA) adopting a more interventionist stance, firms must ensure their AML frameworks are robust and audit-ready.

Colette Best, former Director of AML at the SRA and now a consultant at Kingsley Napley, provided invaluable guidance on managing AML risks and preparing for SRA audits.

Key Insights

SRA Audits - A Certainty: The SRA is moving to a cyclical approach, meaning audits are inevitable. And when they do visit, they will want information in short order. The scout mantra ‘be prepared’ was the key message from Best’s session.
Common Weak Spots: Recent SRA audits have revealed recurring issues such as:
- Gaps in firm-wide risk assessments (FWRAs).
- Discrepancies between policies and processes.
- Weaknesses in ongoing monitoring of client and matter risks.

Practical Takeaways

To navigate the growing complexity of AML compliance, Best recommended the following:

Centralise Documentation: Maintain a central AML folder containing essential documents such as policies, firm-wide risk assessments, training records, and audit findings. Include marked-up versions to demonstrate changes over time.
Mock Interviews: Prepare key personnel for SRA visits by conducting mock interviews and ensuring familiarity with AML documentation and processes.
Prompt Action on Findings: Address SRA findings swiftly and thoroughly, as follow-up visits are likely for firms flagged as high-risk.
Independent AML Audits: Regular external audits can help identify gaps and ensure compliance.

SRA Thematic Review Reminders

2023 Review on Client and Matter Risk Assessments: Every matter should have a complete and accurate client/matter risk assessment – evidencing that controls are operating in practice.
2024 Review on Training: Effective AML training should focus on practical application, using case studies to bring regulations to life. Firms should capture records of all training activities, including newsletters, risk assessment updates, and formal sessions.
Upcoming Thematic review on Source of Funds/Wealth to be published autumn 2025: Look out for new guidance coming in the autumn. At this point you will want to ensure your policies and procedures for verifying source of funds and wealth are up-to-date and functioning effectively. Conduct spot checks to assess compliance and record-keeping.

Final thoughts

AML is a concern for the vast majority of firms for a reason. Even where you are doing the right thing, it’s important to be able to evidence that.

Maintaining good records – and, whether manually or electronically, having central access to good MI – is invaluable.

Regularly sharing AML data with the management board can help embed good data practices, whilst also evidencing an active oversight of AML and associated risks.

For more information:

Client & Transaction Onboarding - Miller

SRA | What does my firm need to do? | Solicitors Regulation Authority

SRA | Anti Money Laundering Training – Thematic Review | Solicitors Regulation Authority