1. Putting the SRA’s focus on AML compliance into context Stephen Wilmott and Sam Palmer 26 th November 2014

2. Why do we need to do this ? Increase in reports Substantial cases Increased interest from Law enforcement

3. Financial action task force (FATF) inspection 2016 Recent EU directive should become ML Regs in UK 2015 1) Individual risk assessments 2) Domestic politically exposed persons (PEPS) – extension to 18 months External drivers

4. SAR numbers – reduction in SAR from the profession by 8% (1 % of all SAR) SAR quality Refusing SAR on quality Government drive on ‘Professional Enablers’

5. Professional Enablers New initiative – government led Organised Crime Strategy - October 2013 Solicitors, Accountants NCA – enforcement – Professional Enablers Working Group Home Office – prevention and awareness programme – targeting the profession New legislation – Spring 2015 – Participation offence

6. What are we doing ? Preparing for FATF AML Working Group Engaged with External Stakeholders Working towards UK and Legal sector compliance Members of MLAC/NRAB Focus work with firms Between early September – May 2015 Open and transparent process – Risk Outlook

7. What are we looking for MLRO – knowledge and reporting AML systems and procedures Record keeping Conversion rates SAR volumes CDD/EDD Training

8. AML workshop Questions Steve Wilmott and Sam Palmer