External AML audits for commercial law firms
The Money Laundering Regulations provide that where appropriate to the nature and size of a practice, it should have an independent AML audit function.
I have developed a methodology as follows, which is flexed to fit the AML plans of my clients:
- Agree a scope and fixed fee (inclusive of expenses if in Central London or Bristol) plus VAT
- Consideration offsite of the client's PCPs and other material
- Attend onsite for CDD file audits and agreed interviews, using the firm's systems and equipment such as a laptop
- Provision of a privileged written report to the MLRO
- Feedback meeting which will cover any topic I find in my audit (not just AML)
I am happy to explain each stage in more detail on a no-obligation basis. I am also happy to work alongside internal audit teams. A 'standard' audit usually takes a total of 5-6 days, with 2-3 of those days onsite. My professional experience has largely been with large commercial law firms, who are national or international: If I feel that I won't be sufficiently expert to audit your firm, I will be honest with you.