Staff Training on AML Legislation and Firm Policy
It is the repsonsibility of the firm, specifically the Compliance Officer for Legal Practice (COLP) and Money Laundering Reporting Officer (MLRO) to provide staff with regular training on the firm's AML policy and any relevant changes to legislation and any updated guidance issued by the SRA or other regulatory body. Refresher training should take place at least annually and training on anything new should be given as soon as practically possible following a change. It is an offence not to train staff and a staff member caught up in suspect activity may be be able to to use lack of training as a defence - in which case the COLP or MLRO is liable to be prosecuted in the staff member's place. The maximum penalty is 14 years imprisonment, an unlimited fine or both, so a law firm's obligations must not be taken lightly.
Reporting Procedures
All staff must be made aware of the proper reporting process where they have AML concerns especially in the event that the MLRO is unavailable (on leave for example). There must always be an individual of sufficient seniority within the firm to whom a report may be made.
