Five Compliance Questions Every Law Firm Should Be Asking Mid-Year
- 2 days ago
- 3 min read
As we move through the year, many law firms find themselves balancing increasing workloads, client expectations and a growing list of regulatory responsibilities.
Whilst annual reviews and accreditation deadlines often attract the most attention, the middle of the year presents a valuable opportunity to step back and assess whether your compliance arrangements remain effective, proportionate and fit for purpose.
A mid-year review doesn't need to be a major undertaking. In many cases, asking a few key questions can help identify gaps before they become issues.
1. Are our AML risk assessments still fit for purpose?
Risk assessments should be living documents rather than something that is completed and filed away.
Consider whether there have been any changes to:
The types of work your firm undertakes
Your client base
Geographic risk factors
Service delivery methods
Emerging threats or regulatory expectations
If circumstances have changed, your risk assessment should reflect those changes.
2. Have we reviewed our policies and procedures recently?
Policies and procedures should evolve alongside your firm.
It's worth considering:
Whether policies remain aligned with current practice
If recent regulatory updates have been incorporated
Whether staff can easily access and understand key procedures
If any processes have changed in practice but not yet been documented
The most effective compliance frameworks are often the simplest and clearest.
3. Are compliance responsibilities clearly understood?
Compliance should never rest solely with one individual.
Whilst designated roles such as COLPs, COFAs and MLROs carry specific responsibilities, effective compliance relies on engagement across the entire firm.
Consider whether:
Staff understand their responsibilities
Reporting lines are clear
Key compliance roles have sufficient support
Compliance remains visible within the wider business
A strong compliance culture is built through shared responsibility.
4. Is training up to date and relevant?
Training remains one of the most effective ways to manage risk.
However, effective training is not simply about attendance records.
Ask yourself:
Does training reflect current risks?
Is it relevant to specific roles?
Have new starters received appropriate training?
Are lessons from previous audits or reviews being incorporated?
Training should help people apply compliance requirements in practice, not simply understand them in theory.
5. Are we prepared for regulatory change?
The regulatory landscape continues to evolve.
Whether changes relate to AML obligations, regulatory guidance, governance arrangements or wider compliance requirements, firms benefit from keeping one eye on the horizon.
Being aware of potential developments early allows firms to plan, allocate resources and adapt in a measured way rather than reacting under pressure.
Remember that reviews are not always driven by the calendar.
Whilst schedule annual or mid-year reviews provide an excellent opportunity to assess your compliance framework, it's equally important to recognise that many updates simply cannot be planned. New Money Laundering Regulations, revised Legal Sector Affinity Group (LSAG) guidance, SRA warning notices and guidance, Law Society practice notes, emerging risks and lessons learned from audits or incidents should all act as immediate triggers to review your risk assessments, policies, procedures and training. Firms should also remain mindful of the ongoing obligations attached to quality standards and accreditations such as Lexcel and The Conveyancing Quality Scheme (CQS), both of which expect firms to maintain up-to-date systems rather than waiting for the next scheduled review.
The most effective compliance frameworks are those that remain responsive, using regulatory developments and quality standards as catalysts for continuous review, timely updates and meaningful staff training throughout the year.
Final Thoughts
Compliance does not need to be complicated, but it does require regular attention.
Taking the time to ask these five questions can help firms identify areas for improvement, strengthen existing controls and approach the remainder of the year with greater confidence.
Strong compliance frameworks are rarely built through major overhauls. More often, they are the result of consistent review, practical processes and a commitment to continuous improvement.
Tracy Thompson is an independent compliance consultant and trainer who supports law firms with AML, CQS, Lexcel and wider regulatory compliance requirements.
If your firm would benefit from a review of its AML framework or practical support with AML compliance controls, please feel free to get in touch.
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