Individual Fines for MLRO's

There is now a risk that a law firms MLRO (Money Laundering Reporting Officer) will be personally fined if they do not insist on having adequate procedures in place so that anything (or anyone) suspect will be reported to them by colleagues although currently this is only applies to firms who are regulated by the FSA as well as the Law Society.

The FSA (Financial Services Authority) have handed down its first fine under the new rules and although they do not expect to be making prosecutions as a matter of course they have been empowered to make professionals take this matter very seriously and face up to the responsibilities involved.

Last week Sindicatum Holdings were fined £49,000 and their Money Laundering Reporting Officer was fined £17,500 personally for not having adequate procedures for controlling money laundering risks even though no evidence of actual money laundering was found.

Although this has started with the financial institutions it is a big wake up call to all law firms. I am just off to check our procedures now.......