With their roots dating back to the early 19th century, Weightmans is a top 40 UK law firm, which employs more than 1,400 staff working across the UK to deliver exceptional law services.
We sat down to chat with Michelle Garlick, named by one client as ‘The Rockstar of Compliance’, to chat about what considerations she took into account when helping Weightmans to set up their AML processes, and ensuring their compliance programme is top tier.
What are the key considerations when establishing an AML program?
The aim has to be to make the onboarding process as smooth as possible for both your clients and the firm, whilst also ensuring that it is compliant with the money laundering regulations.
To do this, you need to:
- Understand your firm, its clients, its people and its AML risks.
- Understand what and where the “pain points” are for your teams and clients during the onboarding process.
- Know what the regulations expect of you
- Where using technology, understand what the provider is offering, what it can (and can’t) do and how it will work for your firm in practice
On top of this, data security is also key.
What challenges did you encounter during the setup process, and how did you overcome them?
Having had an established onboarding process already, one of the main challenges was to work out how to implement a new process with as minimal disruption or change as possible. We consulted with fee earners about the pain points (mainly the time involved for them in working out what ID was needed, obtaining and verifying that ID), involved the process and business change team to understand the changes needed to our case management system, circulated written comms detailing the new process, attended team meetings and held a number of meetings with First AML so that our central AML team could fully understand the use of the platform.
There will always be some resistance to change (even when it is for their benefit). The challenge is to communicate what is going to happen as clearly as possible, listen to feedback, understand where any obstacles to getting “buy-in” might be and address them (if possible).
What are some best practices or standard operating procedures you would recommend for businesses starting their AML journey?
Each firm will have different needs and any AML programme has to be bespoke to each firm (hence the need to understand the firm, clients and people). That said, I would recommend the starting point should be the money laundering regulation and your industry/sector guidance, such as the LSAG guidance for law (the high level compliance principles at the start of the guidance is a great checklist).
Another best practice recommendation I have is to have an independent AML audit carried out which will pick up any gaps in your processes – it is a requirement of the regulations anyway, and a gap analysis will then help you identify where your programme is lacking or needs further attention. This will inform you when identifying tools and tech providers which will suit your practice, and of course budget.
And finally, speak to other MLROs for possible recommendations of providers.
What final advice would you give to your younger self when setting up an AML program, knowing what you know now?
Apart from “don’t agree to be the MLRO!”, be a bit more prepared for some pockets of resistance to change! Accept that you can’t please everyone all of the time but take comfort from the fact that the number one priority has to be to keep your firm safe from money launderers - and your regulator!
About First AML
First AML is an AML technology provider, and the maker of Source, an all-in-one AML platform. Source powers thousands of compliance experts around the globe to reduce the time and cost burden of complex and international entity KYC. Its enterprise-wide, long term approach to the KYC / CDD data lifecycle addresses time and cost challenges while minimising compliance, reputational and security risks.
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