Every SRA-regulated firm has to complete it. Most firms find at least one section harder than they expected.

Each summer the SRA runs its annual anti-money laundering and sanctions data collection exercise. Every firm it regulates has to respond — including firms that do no AML work at all, who must file a nil return. It is a regulatory requirement, and the SRA has been explicit that where firms do not complete it, "we may take regulatory action."

We complete the questionnaire for firms. It is one of the most straightforward things we do, and one of the most frequently requested.

What the exercise actually asks for

The questionnaire runs to 34 pages in its specimen form. It gathers information on three things:

• work your firm carries out within scope of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
• any contact or involvement your firm has with the sanctions regime, and with persons designated under it
• suspicious activity reports your firm has submitted to the National Crime Agency

The SRA collects this because its own regulator, OPBAS, requires it to supervise the profession on a risk-based footing. The data shapes where inspections go next.

The point firms most often miss

The sanctions section applies to everyone. The AML section only applies to firms doing work in scope of the money laundering regulations — but sanctions compliance is not optional for anybody, and it carries strict liability.

In our experience that comes as an unwelcome surprise to firms who have never treated sanctions as their problem. If your answers to the sanctions section reveal that your firm has no sanctions policy, no screening procedure and no documented approach to a positive match, you have told your regulator so in writing.

That is worth thinking about carefully before you submit, not afterwards.

Who is allowed to submit it

The form has to be completed by someone holding one of these roles at your firm:

• Compliance Officer for Legal Practice (COLP)
• Compliance Officer for Finance and Administration (COFA)
• Money Laundering Reporting Officer (MLRO)
• Money Laundering Compliance Officer (MLCO)
• Authorised signatory

You will need a current mySRA account with the relevant role recorded against your firm. The form itself sits on a separate system from mySRA — it uses the same login credentials but you cannot reach it through your mySRA account. If you hold roles at more than one firm, each firm needs its own submission.

Where firms get stuck

• Data that does not match the question. Firms store matter and turnover information in all sorts of ways, and the SRA's categories rarely map onto them neatly. The SRA will accept a considered estimate — but an estimate you can explain is very different from a guess.
• Percentage-of-turnover questions. Work that accounts for more than 0% but less than 1% is rounded up to 1%. Boundaries round up to the nearest whole number.
• Trusts. Making provision for a will trust when drafting a will is not, in the SRA's view, within scope. Acting as a trustee, or managing assets under a will trust, is.
• Client account questions. Operating a client account purely to receive and pay out litigants' settlement monies, court awards, or counsel's fees does not by itself amount to managing client money under the regulations.
• Login and authenticator problems. Every year firms leave this to the final week and discover their authenticator app no longer works on a device they have since replaced.

How we help

Completion of the SRA questionnaire — £180 + VAT. You send us your information; we complete the return and walk you through it before it is submitted. Straightforward, fixed fee, done.

Where the questionnaire exposes a gap — and it often does — we can also help with:

• Sanctions training for your team
• An AML and Sanctions Manual customised to your firm
• AML training
• A review of your firm-wide risk assessment

If your answers worry you

The questionnaire is not a test you pass. It is a description of your firm that your regulator keeps and acts on. If completing it has shown you that your policies, your risk assessment or your sanctions position are not where they should be, the sensible response is to fix that now, in your own time, rather than during an inspection.

That is the work we do every week. Talk to us.

Contact us using the form or email [email protected]