Risk assessing the firm
The firm has carried out a Practice Wide Risk Assessment (PWRA) as required by the Money Laundering Regulations. This document assesses the risks of the firm being used for financial crime and sets out the controls we have in place to mitigate those risks.
Our current PWRA concludes that, after applying appropriate mitigations:
- The firm's residual risk of involvement in money laundering is medium to low.
- The firm's residual risk of involvement in terrorist financing is low.
- The firm's residual risk of involvement in proliferation financing is low.
We are generally considered a low-risk firm because:
- We tend to know our clients well, with many being longstanding or following our lawyers from previous firms.
- Our work typically involves mid-market transactions, with values usually between £1 million and £25 million.
However, this does not mean that individual matters or clients cannot present higher risks. You must:
- Review the PWRA as part of your compliance induction.
- Take the firm's overall risk profile into account when conducting your Client/Matter Risk Assessment.
- Pay particular attention to matters that are unusually large, unusually complex, or inconsistent with the firm's normal client base or transaction profile.
If you identify higher-risk factors or anything unusual, you must flag this in your Client/Matter Risk Assessment and escalate to the MLRO for guidance