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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.