Compliance Lifeline: April 2024
Enderley Consulting Limited
SRA compliance experts supporting law firms with help and guidance. A helping hand for your MLRO, COLPs and COFAs.
Hello and welcome to the April edition of Compliance Lifeline!?
Things have been a little quieter on the law firm compliance front lately, with SRA output focusing on support for in-house solicitors, progress with the Solicitors Qualifying Examination (SQE), and a new review of ‘consumer’ protections. That said, the SRA’s AML audits and investigations proceed apace, prompting a lively debate in the profession about the inconsistencies of fines for non-compliance.
Here are four takeaways for April that we’d urge you to give consideration to for your practice.
SRA Money Laundering Sectoral Risk Assessment
The SRA (as supervisor of AML compliance in authorised firms) has recently published its updated money laundering sectoral risk assessment. Drawing on the latest UK Government National Risk Assessment, this document identifies the risks that law firms are most likely to encounter. But what are the key changes of the SRA Money Laundering Sectoral Risk Assessment?
The SRA has highlighted four new risks. You can read more here
SRA’s firm reminder about Client Account Interest Policy
In the April 2024 SRA Update, the regulator fires a warning shot across the bows of authorised firms: ‘If we have evidence that firms are failing to account fairly, we will take action’.
The article refers to Rule 7 of the SRA Accounts Rules, which requires firms to ‘account to clients or third parties for a fair sum of interest on any client money held by you on their behalf’.
Here are our thoughts on what law firms should be doing to tackle this grey area:
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The taxing issue of VAT on disbursements
In keeping with this month’s theme of accounting matters, VAT on disbursements remains a thorny issue, and in talking to our clients we have detected considerable uncertainty and inconsistency.
Legal Ombudsman shares views on effective complaint handling
The Legal Ombudsman has published its draft Business Plan for 2024-2025, and it contains some useful insights for law firms. Here's our view on it, and four things you should have in mind to bolste your firm’s internal complaints handling procedure:
That's it for April. As ever, if you have any questions arising from any of our articles this month, don't hesitate to get in touch with any one of our team.