The setup
Every law firm in the United Kingdom and the European Union must identify its clients, find the people behind them and assess the risk before it acts. In England and Wales the supervisor is the SRA, and it now inspects or reviews close to a thousand firms a year.
- 935AML supervisory engagements by the SRA in 2024-25SRA, Anti-Money Laundering Annual Report 2024-25
- 1 in 3firms rated after inspection or review were non-compliantSRA, Anti-Money Laundering Annual Report 2024-25
- £1.5min AML fines and settlements in the same yearSRA, Anti-Money Laundering Annual Report 2024-25
The problem
Most firms do the checks. Fewer do them completely, and fewer still can show when each one was done. The failures the SRA finds are not exotic: a risk assessment missing from the file, a source of funds check never recorded.
833 firms rated by the SRA, 2024-25
- Compliant 13%
- Partially compliant 54%
- Non-compliant 32%
Of 5,873 client files reviewed, the share with a check missing
How it is done today
A fee earner or the compliance officer runs it by hand, in pieces, over days.
- 01
Email the client for documents
and wait
- 02
Look up each register on its own site
company register, ownership, sanctions, VAT
- 03
Score the risk in a spreadsheet
no version, no reasons kept
- 04
Re-type it into the firm's forms
the same facts, a second time
- 05
The partner signs
with no record of when each check was made
What we built
Diligentia reads the registers first, asks the client only for what the registers cannot provide, and fills in the firm's own compliance documents. Every fact carries its source and the time it was read. A lawyer approves before anything is produced.
-
01
The matter is opened
- Client
- Matter type
- Jurisdictions
- Parties
-
02
Registers are read first
- Company register
- Ownership chain
- LEI
- VAT
- Sanctions
-
03
Gaps go to the client
- One link
- Documents
- Answers
- Checked on receipt
-
04
The rule pack rates
- Firm's own procedures
- Versioned
- Reasons kept
-
05
A lawyer approves
- Identification sheet
- Indicator list
- Risk file note
The result
The same check, with the record the supervisor asks for built in.
| Step | Today | With Diligentia |
|---|---|---|
| Register checks | By hand, site by site | Read first, each with the time it was made |
| Client documents | Email back and forth | One link, checked on receipt |
| Risk assessment | A spreadsheet, unversioned | The firm's rule pack, versioned, reasons kept |
| The forms | Re-typed | The firm's own forms, filled in |
| Sign-off | Nothing to show the supervisor | A lawyer approves, every fact with its source |
In pilot with a law firm, in its own installation in the EU.
Run it on your own onboarding file.
If your firm wants to test a source-linked onboarding check on its own documents, we would like to hear from you.
info@vantapointlabs.com