The Solicitors Regulation Authority (SRA) has published a thematic review on AML training requirements for law firms. This has resulted in a highly practical and useful checklist for firms to use and implement, highlighting the critical role of staff training in preventing money laundering and protecting firms from regulatory and criminal risks. The findings emphasise that while most firms acknowledge the importance of AML training, many fall short in implementation, record-keeping, and engagement.
This article breaks down the key findings, regulatory expectations, and best practices, providing a roadmap for strengthening your firm’s AML defences.
Why AML Training Matters
Anti-money laundering (AML) training is not just a formality—it is a first line of defence against financial crime.
AML training is only effective however, when it is properly designed, regularly refreshed, and tailored to the specific risks a firm faces. The SRA’s thematic review has highlighted notable compliance gaps across the sector, reinforcing the need for law firms to reassess their approach to AML training.
Key Findings from the SRA’s Review
Between April 2022 and April 2024, the SRA conducted nearly 400 on-site inspections and spoke with 65 major law firms and sole practitioners to assess how well firms are complying with AML training requirements. The results paint a concerning picture, revealing areas where firms are falling short and what needs to change.
Training Quality Directly Impacts Compliance
One of the most striking findings is that firms where the Money Laundering Compliance Officer (MLCO) had received additional training were 50% more likely to be compliant than those where the MLCO had not undertaken further education. This demonstrates that the depth and quality of training matters—simply meeting minimum training obligations is not enough.
Firms that invested in interactive, ongoing training also saw far better engagement from their staff. When AML training is delivered in a way that encourages discussion and real-world application, employees are more likely to retain the information and put it into practice.
A Narrow Focus on Regulations Can Undermine Effectiveness
Many firms continue to deliver training that is heavily focused on the technicalities of compliance rather than on the practical realities of identifying and preventing money laundering. While it is essential that employees understand the legal requirements, training that fails to demonstrate how these rules apply in practice leaves firms vulnerable.
The most effective training programmes incorporate real-life case studies and interactive elements to help staff understand how suspicious activity may appear in everyday transactions. Without this, fee earners may struggle to apply their knowledge in real-world scenarios.
One-Off Training Sessions Are Insufficient in isolation
Another concern raised by the SRA is that many firms treat AML training as a one-off annual event, rather than as a continuous learning process. When training is delivered infrequently, staff knowledge deteriorates, making it easier for suspicious activity to go unnoticed.
Firms that implement ongoing refresher training—rather than relying on a single session per year—ensure that staff stay alert to evolving risks and regulatory updates.
Generic Training Packages Don’t Address Firm-Specific Risks
A common mistake made by law firms is relying solely on generic, off-the-shelf AML training packages. While these can provide a good baseline, they often fail to reflect the specific risks faced by individual firms.
A firm dealing primarily with high-net-worth individuals, international clients, or corporate transactions faces very different money laundering risks than a firm focusing on small-scale property transactions. Training should be tailored to align with a firm’s practice areas, client base, and geographic risk exposure.
Some firms are now commissioning bespoke AML training that reflects their unique risk profile—a move that the SRA strongly encourages.
Poor Record-Keeping Remains a Major Issue
Another area of widespread non-compliance is record-keeping. Of the firms inspected by the SRA, 42 were found to be non-compliant, with inadequate documentation of training activities being one of the most common failures.
Under Regulation 24(1) of the MLRs, firms must keep comprehensive records of:
• Training materials (such as presentations, notes, and handouts).
• Attendance records to confirm who has received training.
• Dates of training sessions to ensure regularity.
• Assessment results to measure staff understanding.
Without proper documentation, firms cannot prove compliance to regulators, increasing the risk of enforcement action.
Final Thoughts: A Call to Action for Law Firm Leaders
AML training is not just about meeting regulatory obligations—it is about protecting your firm, your clients, and the wider legal system from financial crime. The SRA’s thematic review makes it clear that many firms need to improve the quality, frequency, and record-keeping of their AML training programmes.
Immediate Actions to Take
✔ Review your firm’s AML training programme against the SRA’s findings.
✔ Ensure all relevant staff receive ongoing, tailored training (not just generic sessions).
✔ Keep comprehensive records of all training activities.
✔ Monitor compliance regularly to ensure staff can identify and report suspicious activity.
Resources
✔ SRA Guidance on AML Training: SRA | Anti Money Laundering Training – Thematic Review | Solicitors Regulation Authority
✔ AML Training Checklist (PDF Download): https://www.sra.org.uk/globalassets/documents/sra/research/aml-training-checklist.pdf
✔ Law Society AML Resources: Anti-money laundering guidance for the legal sector | The Law Society