Compliance Audit | Teal Compliance

Why the boiling frog syndrome speaks to law firm AML compliance needs

The Boiling Frog of AML Compliance

Anti-Money Laundering, Audit, Blogs, Compliance Webinars, Legal Compliance, Regulatory Compliance, Risk Management / Mark

Imagine a frog in a pot of water that warms imperceptibly over time. It’s a familiar parable about gradual danger, and it offers a stark lesson for law firms on the subject that we know and love … AML compliance!

In practice, poor anti-money laundering controls usually creep in slowly. Look, we’ve all been there in any walk of life with managing risk, however, small risks accumulate until one day you realise you’re in hot water.

Solicitors, lawyers and senior partners may grow used to cutting a corner here or there, for example, delaying full risk assessments on every small conveyancing deal or skipping a detailed client check to close a sale, and find nothing bad happens, so they think it’s safe. All the while, your compliance officer is trying to juggle the balls and spin the plates without being aware there are niggling potential risks and breaches going on behind the scenes.

Our very own Amy Bell recently ran a webinar for Locktons and spoke passionately about Client Matter Risk Assessments and the need to be proactive.

We have to remember that the regulatory temperature is rising. The SRA reminds firms that any matter in scope triggers obligations…

“no matter how short in duration or scope… the appropriate level of client due diligence and a risk assessment must be carried out”

SRA

In other words, there is no de minimis exception. If firms relax standards bit by bit – trusting the status quo, relying on old practices, or failing to update their policies – they risk essentially sitting in tepid, heating water without noticing.

How do you know if you’re in scope? Read the SRA’s guidance HERE.

Money Laundering’s Slow Burn

Money laundering itself can be surprisingly mundane and routine. The work is insidious, yet subtle.

Economic and financial criminals (or the #baddies as Amy Bell calls them) increasingly move large sums through seemingly legitimate channels. How delightful are your client accounts for them? Sadly, the usual targets for money launderers are property purchases or corporate transactions, where dirty money is effectively “laundered” into the system.

In an era of high-value deals, even honest clients may inadvertently carry illicit funds, and it’s our job, as legal professionals, to spot them. Sadly, we’ve seen all too often, when firms become complacent there is a danger that suspicious activity is seen as a normal part of business, not a warning sign.

Cultural norms can creep in. If you’re a lawyer in a busy commercial team you might think that because you’ve dealt with a well paying client for years it’s ok to maybe wing the CDD and SOF checks.

You know them, have a great working relationship with them, might be a top biller because of that relationship. Why bother with lengthy ID checks every time? It’s the source of funds and the source of wealth you really do need to verify. If you are a junior associate or new to the role of COLP or MLRO, are you brave enough to challenge a partner’s relationship with a client who brings in vast amounts of funds into the firm?

Colleagues may joke about being bureaucrats or delay refreshers on training, reinforcing the idea that compliance is low priority. This is exactly the mindset that lets the pot warm up unnoticed. The SRA’s fining powers are in full use and rather than being complacent, wouldn’t it be better to maintain continual vigilance?

If AML controls slack then your risk indicators could drop to the bottom of the pile or worse, be forgotten.

Over time, your firm’s overall money-laundering deterrence is weaker, even though the actual work and transaction values stay high.

Our TEAL TRACKER is perfect for continued and effective reminders and alerts.

How to Master the Tricky World of the Source of Funds and Wealth

This is a great blog to read to help you with any awkward conversations!

Law Firm AML Complacency, Culture and Drift

By the time someone in the firm notices a problem, the culture of complacency may be too rooted as there’s been a resistance to change. Recent SRA enforcement highlights firms that have languished in non-compliance for years before a regulator stepped in.

We get it, practicing law, dealing with clients, dealing with partners, dealing with the other side and let’s not get started on the billable targets are exhausting enough, but whether you like it or not, compliance is your best friend.

You probably have read cases such as the law firm who repeatedly omitted conveyancing (75% of its work) from its firm-wide risk assessment. That omission persisted even after the firm had told the SRA its risk assessment was compliant back in 2020. It only implemented proper controls after an SRA inspection – long after the drill of neglect had set in.

The regulator noted that this firm’s failures (no independent audit, weak transaction monitoring, even a lack of partner training) “showed a disregard for statutory and regulatory obligations”. In blunt terms, the SRA said the firm’s problems “could have been avoided” by doing a proper risk assessment from the start . It fined them £20,000 and raised the fine to send a deterrent message.

So when we talk about the boiling-frog metaphor, the above example is a classic.

The firm didn’t collapse suddenly. Instead, year after year it failed to address its internal gaps. The First AML analysis of 2025 disciplinary cases makes the same point that firms with “systemic gaps” and “long-standing… compliance failures” have faced the harshest penalties. The highest fine to date was £27,813 – given for “widespread AML failures” including inadequate risk assessment, precisely the kind of entrenched lapse that happened slowly over time.

In total,16 out of 50 SRA disciplinary decisions recently related to AML breaches, with over £61k in fines imposed. The takeaway is clear in that persistent neglect of AML duties is now being punished, but it really doesn’t have to be onerous with training updates, easy software reminders, or outsourced compliance (see our SORTED programmes for different sized firms). Problems often build silently (thanks to shifting workplace culture or understaffing), but ultimately the SRA will notice and step in.

Regulatory Guidance and Enforcement

Fortunately, the guidance is clear – if only firms heed it, plus we are here, literally guiding and holding your hand.

In April 2025 the Legal Sector Affinity Group published a new AML guide (approved by HM Treasury), officially governing SRA firms. This updated LSAG guidance reiterates the basics that every firm needs a firm‑wide risk assessment, clear policies and procedures, up‑to-date CDD (customer due diligence) processes, and continuous training.

If you or your colleagues have received any of our training you’ll know that we really are experts and give practical advice that goes above and beyond the tick box boring exercises.

Regulators now stress that proactive compliance is the norm, it’s just how it is, which is why Amy and the whole team here at Teal Compliance are passionate about supporting firms and allowing their compliance officers a safe space to comply.

Analysts advise firms to focus first on a comprehensive, regularly-reviewed risk assessment (covering the firm itself and each type of client/matter).

Your policies and internal controls should be robust and embedded in daily work, not siloed documents on a shelf.
Staff training must be ongoing – the guidance emphasises that AML education is not a one-off checkbox but a continual process (for everyone from juniors up to partners).

The SRA underscores that being in scope is about the services provided, not simply holding client money, meaning that your law firm can’t slip below the radar by reclassifying work. Don’t forget, the SRA explicitly warns firms that even a short, simple matter can trigger full obligations.

What does this mean in practice? Simply put, law firms seriously have to work on cultivating an alert, risk-based culture, with the “tone from the top” view of compliance as an integral part of quality practice.

Our webinar with Amy Bell and Simon McCrum and what a partner looks like when it comes to culture, cashflow and compliance is worth a watch. WATCH HERE.

If a potential red flag arises (for instance, unusually large cash payments in conveyancing, or a client reluctant to provide full information), it must be treated as out-of-ordinary, not routine.

Time to Jump out of the Boiling Pot?

None of this blog is intended to alarm you and your colleagues, rather, it’s a wake-up call wrapped in a familiar metaphor.

By considering where your firm stands in that rising temperature, you can decide whether it’s time to jump. Are you reviewing risk assessments as new risks emerge (for example, new regions, new products, or new high-value clients)? Are your AML procedures championed by leadership, not seen as a grudge task? Do teams feel able to raise concerns (flipping the narrative from “Why question this again?” to “Yes, we need to check”)?

“Jumping out” means acknowledging any complacency or resource squeeze and taking action early. Can you add more staff to your compliance team? Does your current compliance officer cover COLP, COFA and MLRO and if so, what training and support do they receive? Can you organise refresher training? Are you in a firm that allows honest conversations about a healthy culture and therefore better risk management?

The updated SRA/LSAG guidance is on your side because it offers case studies and practical checklists to help identify seemingly innocuous, yet insidious gaps.

Why not embrace our advice and that of the SRA and the LSAG, by keeping your pot of water at a comfortably warm temperature, rather than a lethal one! In the end, reminding ourselves of the boiling‑frog fable isn’t scaremongering – it’s about staying vigilant.

What we recommend firms do is to stop and feel the temperature, is the heat rising without being noticed? If so, now’s the time for a quick dive or a firm clear-out of old habits. Jump before it’s too late, not after the pot is boiling.

The Boiling Frog of AML Compliance Read More »

Managing Risk with Mental Health Tips - Teal Compliance support Mental Health Awareness Week May 2025

Managing Risk with effective Mental Health Tips

Anti-Money Laundering, Audit, Blogs, Compliance Webinars, Legal Compliance, Regulatory Compliance, Risk Management / Mark

Reminder that we are not only your training partner but also your outsourced compliance and regulatory partner – find out more here.

The Law Gazette flagged up how the SRA’s got their eye on AML breaches this April, and seeing as it’s Mental Health Awareness Week an’ all, we thought we’d chip in with our two pence. Looking after yourselves and your staff isn’t just a nice thing to do, it’s a smart move for keeping your firm on the straight and narrow with AML and regulatory compliance.

Let’s make sure we’re not ending up on the SRA’s naughty step by keeping an eye out for each other.

With that in mind, here are our Handy Hints for risk management when it comes to culture and mental health.

Make it Safe to Talk - Risk Management Tip No. 1

We strongly recommend that you organise (yes, even prioritise) firm-wide discussions or workshops during Mental Health Awareness Week specifically linking well-being to work performance and error reduction.

We can’t emphasise enough that stress, anxiety, and burnout can significantly impair concentration and judgement. We’ve all been there at different times in our working lives. Working under pressure and in a stressful environment increases the risk of overlooking crucial compliance steps or making mistakes in complex AML processes like Source of Funds checks or client due diligence.

Working in a healthy culture where staff feel comfortable acknowledging when they are struggling is so important! LawCare Charity insights show that those under pressure or in a culture where they are afraid to talk in a safe environment are potentially more likely to make errors due to mental fatigue or stress.

If you don’t believe us, just are your PII contacts!

Promote Practical Wellbeing Strategies for High-Pressure Tasks - Risk Management Tip No. 2

Practical tips and tools to manage stress and improve focus, especially during peak workload periods (e.g., completion deadlines in conveyancing) can be really helpful.

This could include mindfulness exercises, time management techniques, or signposting to Employee Assistance Programs (EAPs) if you have them. Often we see in our audits that targets cause stress, together with the billable hour and WIP not being paid. Do you have mentoring systems in place to alleviate too many matters for one person? It’s easy to take your eye off the ball on one matter, where the SOF hasn’t been checked because the client has been with the firm for many years. Are they a priority? Yes, their checks are a priority, just as practising the law is.

When it comes to AML and regulatory compliance, why not frame the above strategies as tools to enhance accuracy and reduce errors in high-stakes compliance tasks? For example, really simple things like taking short breaks can improve concentration during complex AML risk assessments.

Lead by Example - Risk Management Tip No. 3

As law firm partners we encourage our clients who are senior partners, together with the MLRO/COLPs, to actively participate in Mental Health Awareness Week initiatives and openly discuss their own well-being.

When senior leaders demonstrate that mental health is a priority, it sends a powerful message that compliance and well-being are both valued.

Sending the message throughout the business (and your firm is a business), can reduce the stigma associated with seeking support and encourage staff to prioritise their own mental state. If you know your boss prioritises well-being and family for example, it ultimately leads to more careful and considered compliance practices overall.

By leading by example, senior management teams can foster a supportive and open culture where well-being is seen as integral to professional responsibility at all levels.

Empower with Knowledge - Risk Management Tip No. 4

Why not share resources (internal or external) during the week that explain the connection between mental health and cognitive function, particularly in detail-oriented tasks like regulatory compliance. The NHS has their 10 Stress Busters HERE .

Lockton has some great blogs on Mental Health and how a healthy culture helps keep a law firm’s claims at arm’s length.

In one of their articles, they talk about Psychological Safety.

“Supervision plays a vital role in helping supervisees feel psychologically and emotionally supported at work. In addition to supervising the quality of work, supervisors should encourage discussions about any worries, concerns, near misses, or development needs that their supervisees have. Creating a psychologically safe environment where supervisees feel confident to raise questions or concerns with their supervisor will not only help to mitigate ethical risks but also identify pressures that might be having a negative impact on wellbeing. “

Why HR and Risk Management Teams Should Collaborate on Wellbeing READ HERE

Did you know that conditions like anxiety or depression can affect memory, focus, and the ability to follow complex procedures, such as SAR reporting or adherence to SRA Accounts Rules?

As our own CEO does with Team Teal, why not educate staff on why prioritising their mental health isn’t just a personal matter but a crucial element of maintaining a safe and compliant work environment?

Thanks for reading and if you have any questions on how mental health and compliance are partners for the good, or would like to take advantage of our ASK TEAL service, you can get in touch HERE.

Team Teal

Managing Risk with effective Mental Health Tips Read More »

Regulation 21 and ongoing monitoring article from Teal Compliance

Regulation 21 and Ongoing Monitoring – an AML Compliance Reminder

Anti-Money Laundering, Audit, Blogs, Compliance Webinars, Legal Compliance, Regulatory Compliance, Risk Management / Mark

Rhiannon Davies, Associate and specialist in AML and Regulatory Compliance. This article is a debrief of the webinar and transcript I ran on 2 April 2025. You can watch the recording HERE.

Let’s kick off with AML audits and what the regulations say. Specifically, we’re looking at Regulation 21. It has a few key requirements, but I’ll focus on the part about independent audits.

You can read here about our outsourced AML Compliance and Regulatory Compliance SORTED programmes that cover the requirements too.

Regulation 21 and Independent Audits

We started off the webinar AML audits and what the regulations actually say.

Key requirements of Regulation 21
The role and purpose of independent audits
Defining “independent” and “size and nature”

The first requirement is appointing a Money Laundering Compliance Officer (MLCO). This must be someone in senior management, like a Board Director or equivalent (e.g. senior management). Why? They need to have enough authority to enforce policies, update training, and even decide on the firm’s risk appetite for clients and work types.

The second requirement involves screening employees—both before they join and during their tenure with the firm. I won’t go into detail on this today, but if you’re curious, LSAG 9.4 has some excellent guidance on how to approach it.

Now, onto the third part of Regulation 21—the independent audit function (there are loads of different terms for this function). This is where it gets interesting! Essentially, the audit assesses the adequacy and effectiveness of your firm’s AML policies, procedures, and controls within the firm. If issues are identified, the auditor provides recommendations and follows up to ensure compliance.

But here’s the thing—what does ‘independent’ really mean? And how does ‘size and nature’ factor into whether your firm needs this function? These are questions we get all the time.

‘Size and nature’ isn’t strictly defined in the regulations, which can make it tricky. The SRA, however, suggests that the majority of firms will require an independent audit function. For instance, if your firm handles conveyancing work, it’s almost certain you’ll need one. On the other hand, if you’re a sole practitioner without staff, you can probably justify not implementing one.

As for ‘independent,’ it doesn’t always mean external. That said, achieving true independence internally can be challenging. The auditor mustn’t be someone who sets or follows the firm’s AML policies, however, it needs to be someone with enough knowledge of AML which rules out many internal staff. Often, firms find they need to bring in external specialists to meet this requirement.

So, in summary to this section of the webinar, I said that if your firm doesn’t already have an independent audit function, now’s the time to assess your needs. And if you’re unsure where to start, I’m happy to point you toward some useful resources. Please feel free to email us: hello@tealcompliance.com

Introduction to Ongoing Monitoring

I’m grouping this with the previous topic because it’s a key area where we often find firms struggle, particularly fee earners. During our AML audits, we consistently observe challenges with the implementation of effective ongoing monitoring procedures. So, I’m going to delve into this in a bit more detail, referencing the regulations themselves.

Ongoing Monitoring: A Deeper Dive

Defining ongoing monitoring and its components
SRA guidance on ongoing monitoring
Challenges in implementing ongoing monitoring

Ongoing monitoring is split into two parts, firstly from a transaction point of view, where you need to keep an eye on the level of risk that the matter and the client is posing to the firm throughout the whole of the matter.

Secondly, it’s the reviewing identification documents for your existing clients and making sure you’re keeping them relevant and up to date. So any of those documents that you’re relying on, if they’ve expired, you’re getting new ones.

When we talk about ongoing monitoring, it involves both of those components.

Defining Ongoing Monitoring

Here’s a summary of the definition of ongoing monitoring – comprising two key components.

Transaction monitoring: this means continuously assessing the level of risk that the matter and the client pose to the firm throughout the duration of the case.
Periodic reviews of client identification documents to ensure their validity. Expired documents, for example, must be replaced.

Therefore, ongoing monitoring encompasses both the scrutiny of transactions and the maintenance of up-to-date client documentation.

SRA Guidance on Ongoing Monitoring

The SRA emphasises the mandatory nature of ongoing monitoring, as stipulated in Regulation 28(11) of the Money Laundering Regulations.

The SRA’s guidance highlights that any communication with a client has the potential to alter the risk profile of the matter, the client, or both.

Consequently, risk assessments should be re-evaluated at appropriate intervals and to reflect any changes in circumstances, such as alterations in beneficial ownership, the nature of the client’s business, or their address.

It’s worth noting that the SRA stresses the significance of ‘any communication‘ in this context. This underscores the need for comprehensive AML training for all staff, including support and reception personnel, as any interaction with a client could reveal suspicious activity. Essentially if any staff has a touch point with your clients, they need training.

The phrase ‘re-evaluated at appropriate intervals‘ requires careful consideration, as its interpretation can vary. While it’s clear that a reassessment is necessary when material changes occur (e.g., third-party funding, newly discovered links to high-risk countries etc), the challenge lies in demonstrating ongoing monitoring when no such changes are apparent.

Challenges in implementing ongoing monitoring

Why do we see so many firms struggle with ongoing monitoring? From our experience and training it looks like this:

Not understanding the purpose of ongoing monitoring
Doing it but not evidencing it, especially where nothing has changed
Not sure when it should be done
Ticking boxes without providing rationale
Not wanting to bother clients further
Forgetting about LSAG

We often hear about re-evaluation at appropriate intervals in ongoing monitoring.What does that exactly mean though, because there’s no definition!

“Best practice and with a risk based approach”, it could mean different things to different people and firms. Ultimately, it means there needs to be an update if anything on the matter has changed. For example, if a third party is now providing funds for the transaction, or say you’ve suddenly discovered the client’s got links to a country outside of the UK that would generally prompt you to relook at the risk assessment. This seems obvious right?

However, what about when nothing’s changed? How do you evidence that? How do you prove you’ve done your ongoing monitoring when absolutely nothing’s changed on the matter and you’re still as comfortable with the risk as you were at the very beginning of the matter?

That’s the bit where we often find we don’t have the evidence when we’re running an AML audit; so when we’re doing some of the file reviews, as a minimum, we’d recommend the following guidance via three points.

Three point ongoing monitoring guidance

Our three point guidance is where you assess the risk and emphasis is on the word minimum.

Think of it as a story because it has a beginning, a middle and an end.

Beginning stage: file opening

At this point, is there anything that you’ve seen or been told that doesn’t quite sit right with you? Are you not sure whether you want to proceed with the matter? Do you need some more information to make yourself more comfortable? Or are you happy to proceed at this time?

Either way, it needs to be noted on your risk assessment. And I must say, the majority of firms that we audit, the opening risk assessment is the one that’s often carried out well.

It’s the next stage where we see failures.

Middle stage – review of CDD documents

I’d normally suggest this part of your ongoing monitoring story is once you’ve reviewed the CDD documents from your client. This is the point when due diligence checks around your client’s evidenced source of funds (SOF) and source of wealth (SOW) are with you.

At this point, you’d be looking if anything has changed at all, i.e. have any risk factors changed from what you decided at the beginning? Does the evidence from your client match what they told you at the beginning? Does everything still make sense? And again, if not, you might need to ask further questions, or you might need to see some further evidence.

If everything is hunky dory, carry on and proceed with your matter. HOWEVER, don’t forget to document and evidence your checks and confirmations.

Even if nothing’s changed, documenting that you have still assessed that risk again, would evidence ongoing monitoring. Then I suggest a final risk assessment.

End stage – last minute changes

An assessment of the risk again, before you proceed with whatever it is that you’re doing that could end up being money laundering.

Before the actual transaction takes place (e.g. in conveyancing), before any money’s moved you have evidenced your final risk assessment.

Remember, the baddies are waiting for any last minute changes in the hope that you don’t ask any questions.

Financial criminals and money launderers thrive on last-minute transaction changes, banking on lawyers being under pressure to push deals through without thorough scrutiny. They count on urgency preventing deeper AML checks, allowing them to disguise their true source of funds or wealth. The pressure conveyancers were under in March because of the changes to Stamp Duty, was horrific, the baddies would have been rubbing their hands with glee.

Come what may, you have to maintain vigilance with risk assessments and ongoing monitoring whilst documenting every step to justify risk ratings. If it’s not written down and evidenced, in essence, it didn’t happen. You hear time and time again about SRA inspections and their fining powers when swooping in to check.

Practical Guidance on Risk Assessment Frequency

As a reminder on some practical tips to help with your ongoing monitoring for risk assessments, we’d say never to focus on thinking that after your initial first step of onboarding CDD to continue checking on changes or documents that don’t match your original docs.

Our recommendations would be:

Initial Assessment: This is conducted when the file is opened. At this stage, the primary focus is on determining whether to accept the client and, if so, the appropriate level of Customer Due Diligence (CDD). Any initial concerns or uncertainties should be thoroughly documented.
Interim Assessment: We advise conducting this assessment after reviewing the client’s CDD documentation, including source of funds and source of wealth evidence. The aim is to verify the consistency of the evidence with the client’s initial representations and to identify any emerging risk factors.

LSAG offers helpful guidance on documenting ongoing monitoring, including the issues considered, actions taken, reasons for decisions, and details like dates and individuals involved. Monitoring also involves reviewing and renewing client identification documents, especially for ongoing or long-term clients. Having said that, when reviewing client identification documents, it doesn’t mean you need to ask the client for them again for every matter but they must be reviewed for relevance and validity, such as checking for expired documents.

Challenges in Implementing Ongoing Monitoring

Changes in beneficial ownership, particularly further up the corporate structure, may not be immediately apparent, which makes ongoing monitoring crucial.

For corporate clients, drawing up a structure chart at the beginning of the relationship and confirming it at each new matter is really good practice. This would help with ensuring the beneficial ownership remains consistent. If a change is identified, such as a new beneficial owner, then you must follow appropriate identification and verification processes in line with your firm’s policies and procedures.

We get it, struggling with ongoing monitoring is common, which is why my colleagues and I want to support you and your colleagues.

Challenges range from a lack of understanding of the actual purpose of ongoing monitoring, assumptions based on long-standing client relationships, and inadequate documentation. For instance, staff might simply tick a box to indicate monitoring without detailing the rationale or evidence. There’s also a hesitation to bother clients for updated information, fearing complaints or loss of business.

My advice is clear, would you go to prison for a client? No – it’s not worth it.

I hope you found this blog helpful, and do watch the recording if you have time.

Rhiannon

Regulation 21 and Ongoing Monitoring – an AML Compliance Reminder Read More »

What does beneficial ownership mean for AML compliance

What does Beneficial Ownership mean for law firm AML compliance?

Anti-Money Laundering, Audit, Blogs, Legal Compliance, Regulatory Compliance, Risk Management / Mark

Whether you’re based in the UK or Australia (where our sister firm AML Sorted is based), are a law firm whose areas of law offer corporate and commercial law, you’re going to need to know what Beneficial Ownership means.

The UK and Australian governments and regulatory bodies are pretty clued up on these risks, which is why they’ve brought in some stringent anti-money laundering (AML) regulations. Understanding beneficial ownership information is a central requirement of those regulations, and it’s critical to your firm’s AML compliance and control structures.

Understanding beneficial ownership
Definition of an individual PSC of a UK company
Definition of a beneficial owner of an overseas entity
Examples of concealing beneficial ownership
Don’t rely on the corporate veil — lift it
Challenge vague answers
Document the risk rationale
Verify control, not just ownership
Watch for layered structures
US Legislation News

Understanding beneficial ownership

When we talk about ‘beneficial ownership,’ it’s all about figuring out who really owns or controls something, whether it’s a property or a company. It’s not just about the names on the official paperwork, ie…. the ‘legal owners.’ For specialists like us at Teal Compliance, and AML Sorted, we’re like detectives, digging deeper and deeper until the ownership and control is truly transparent. In another life instead of solicitors and AML compliance experts we’d be investigative journalists!

In the world of property and conveyancing, as an example, we’ve got to identify and check who’s actually pulling the strings and getting any benefit from a property deal, even if they’re not the ones listed on the deeds. Our job in AML compliance is to support you, the law firms and the MLROs, protect your bottom line and your reputation whilst ensuring financial criminals are held to account.

Identifying beneficial owners is really important when we’re trying to stop money laundering because criminals are sneaky. They often hide their dirty money by owning entities that are set up through complicated setups like shell companies and trusts. It makes it really hard for anyone to trace where the money really came from.

In this blog, when we use the acronym PSC, this means person with significant control.

Definition of an individual PSC of a UK company

In accordance with the Economic Crime and Corporate Transparency Act: beneficial ownership (last updated on 1st March 2024) the definition of an individual PSC of a UK company comes under Schedule 1A, where it states that if an individual (“X”) meets one or more of the following conditions in relation to a company (“Y”), they must be registered as a PSC in respect of Y:

X holds, directly or indirectly, more than 25% of the shares in company Y.
X holds, directly or indirectly, more than 25% of the voting rights in company Y.
X holds the right, directly or indirectly, to appoint or remove a majority of the board of directors of company Y.
X has the right to exercise, or actually exercises, significant influence or control over company Y.
The trustees of a trust or the members of a firm that, under the law by which it is governed, is not a legal person meet any of the other specified conditions in relation to company Y, or would do so if they were individuals, and, X has the right to exercise, or actually exercises, significant influence or control over the activities of that trust or firm.
1. If you want to dig deeper into LSAG’s definition of a beneficial owner when it comes to the topic of TRUSTS, law firms should verify settlors, beneficiaries, protectors, and the assets the trust holds (not just the trustee). You can read more under LSAG Section 6.14.12.2) or of course, get in touch with us or become an ASK TEAL client.

Definition of a beneficial owner of an overseas entity

Under paragraph 6 of Schedule 2 to the Economic Crime (Transparency and Enforcement) Act 2022, a person (“X”) is a beneficial owner of an overseas entity or other legal entity (“Y”) if one or more of the following conditions are met:

X holds, directly or indirectly, more than 25% of the shares in Y.
X holds, directly or indirectly, more than 25% of the voting rights in Y.
X holds the right, directly or indirectly, to appoint or remove a majority of the board of directors of Y.
X has the right to exercise, or actually exercises, significant influence or control over Y.
The trustees of a trust, or the members of a partnership, unincorporated association or other entity, that is not a legal person under the law by which it is governed meet any of the conditions specified above in relation to Y, and, X has the right to exercise, or actually exercises, significant influence or control over the activities of that trust or entity. Note: please reference 5.a above for more information on LSAG and trusts.

Examples of concealing beneficial ownership

The National Crime Agency’s (NCA) news page is full of crimes and it’s worth having a read to keep you and your compliance officers on their toes. The agency always says to keep a look out for changes in client circumstances. Are the international sanctions’ listings checked on a daily basis? If your client is an art dealer or auction house and your diligence measures flag up questions over their source of funds on their artwork, get them to check these red flags:

Attempts to transfer artwork or cultural property ownership to a family member, close contact, business associate or other intermediary, or
Attempts to sell artwork or cultural property quickly, or move it to another jurisdiction.

Be especially vigilant when dealing with front or shell companies, or intricate corporate or trust structures that obscure the ultimate beneficial owner. While it’s tempting to prioritise well-paying, existing clients, the heightened focus on combating money laundering means your firm faces significant risk if you’re flagged for inadequate AML compliance by the SRA.

Definition of Beneficial Owners: those that might benefit from their ownership of an entity or asset (eg a company.) You will need to identify and undertake reasonable measures to verify the identity of your clients, especially when dealing with high-risk clients or transactions.

Don’t rely on the corporate veil — lift it

Always identify the natural person(s) behind any legal entities. Shell companies and complex structures can hide risk — dig and keep digging, until you find the ultimate beneficial owner (UBO), not just the named shareholders.

If you are concerned about upsetting your client, find ways of carrying out your due diligence and be specific and clear about what you need at the outset.

Why not provide a list to your client with the information you need and if they push back have the back up to explain the purpose.

You should always ask for their details – see below (where applicable) to support and evidence your AML processes and controls. The SRA and your insurer will thank you for this….

Shareholder registers
Company structure charts
Trust deeds

Challenge vague answers

Here’s an example of what your MLRO might be up against….

Client: “Oh, the company is owned by a few investors.”

Reply with… “To comply with regulations, we need to identify the individuals who ultimately own or control the company. Could you please provide a list of all shareholders with more than 25% ownership, and details about anyone who has significant control over the company’s decisions? We really want to protect your own interests and this information will support this.”

Document the risk rationale

Keep clear notes on why a client is low, medium, or high risk, especially if beneficial ownership is complex. You’ll thank yourself during audits or inspections.

Our own software, the TEAL TRACKER, supports your documentation and evidence in this regard because it includes a high-risk client register, an undertakings register, incident management tracker, file reviews and more.

Here’s the framework we are aligning ourselves to, and knowing which legislation your tracking and note taking adhere to will help you and your team.

Money Laundering Regulations 2017: These regulations are the cornerstone of AML compliance in the UK and place a legal obligation on firms to identify beneficial owners.

Economic Crime (Transparency and Enforcement) Act 2022: This Act introduced the Register of Overseas Entities, further emphasizing the importance of beneficial ownership transparency, especially in relation to UK property.

Proceeds of Crime Act 2002 (POCA): This is the legal backbone of the UK’s fight against money laundering and places stringent obligations on law firms to be vigilant, to have strong AML controls, and to report suspicious activity.

Companies Act 2006 (in particular Schedule 1A): In this act, it defines “People with Significant Control” (PSCs) for UK companies, which is closely related to the concept of beneficial ownership.

Verify control, not just ownership

Control can be exercised in various ways, and it’s important to look beyond just shared ownership.

A person can be an ultimate beneficial owner (UBO) if they exercise significant control, even if their shareholding is below 25%, for example when your client is an LLP. Check for influence via voting rights, directorships, or veto powers.

Red flags to be on high alert for include:

Nominee Directors or Shareholders: The use of nominees to hold shares or directorships.

Lack of Transparency: Reluctance to provide information or vague answers about ownership and control.

Inconsistent Information: Discrepancies between information provided by the client and information from other sources.

Why not do your research and look into their confirmation statements, do they have information on control of beneficial ownership on their websites, or are Board Minutes available to you?

Check on the Registers for Beneficial Owners website, and run a check on the background and relationships of the company’s directors and senior management.

Watch for layered structures

Multiple holding companies across jurisdictions may indicate masking of the truth! You’d want to understand the chain until you reach a human being. We appreciate that layered ownership structures can feel like untangling a particularly tricky ball of wool, but the key is to break it down step by step—each layer tells part of the story.

What would you do in the following scenarios?

Multiple Layers of Ownership where ownership is divided across several entities, often spanning different jurisdictions (e.g. Company A owns Company B, which owns Company C, and so on).
Use of Shell Companies, which are entities that exist only on paper, with no significant business activities, often used to add layers of ownership without transparency.
Circular Ownership, which occurs when entities within the structure own shares in each other, creating a loop that obscures the ultimate beneficial owner (UBO).
Offshore Jurisdictions are entities registered in jurisdictions with high levels of secrecy and minimal disclosure requirements are often included to complicate tracking.
Nominee Directors or Shareholders (as mentioned above), can be individuals or entities who are listed as directors or shareholders but act on behalf of the true owners without having actual control or interest.
Frequent Changes – watch out for regular changes in ownership, directors, or shareholders because these can make it harder to establish a clear picture of control.
Trusts and Foundations are legal arrangements that can be used to conceal the identity of the true owners by placing assets under the control of trustees or foundations.

The above structures are often red flags for money laundering, tax evasion, or other illicit activities. In these circumstances, your enhanced due diligence (EDD) measures, such as verifying the identities of beneficial owners and understanding the ownership structure, are crucial to back you and your practice up.

US Legislation News For Information

It’s worth noting that the US has also stepped up its efforts in corporate transparency, introducing new provisions that came into effect on 1st January 2024. These rules now require certain corporate entities in the States to report information about their beneficial owners.

Much like the corporate transparency legislation we’ve seen introduced in other parts of the world, including our own measures here in the UK, the overarching goal is to make it tougher for those with illicit intentions to conceal their activities behind shell companies or other murky ownership structures. The hope is that this increased transparency around who really owns and controls these entities will be a significant weapon in the ongoing fight against money laundering and the financing of terrorism.

To wrap this article up, the one thing I urge you to remember, is that it’s up to you to take reasonable measures to verify the identity of the beneficial owner.

For more information on the Register of Overseas Entities, you can click here to read more. The ROE came into force in the UK on 1 August 2022 through the new Economic Crime (Transparency and Enforcement) Act 2022.

Thanks for reading and if you have any specific questions on this subject or would like to take advantage of our ASK TEAL service, you can get in touch HERE.

Tom Hughes

Senior Associate

What does Beneficial Ownership mean for law firm AML compliance? Read More »

SARs - understanding suspicious activity with key insights and reporting tips from Teal Compliance and Amy Bell

SARs – Understanding Suspicious Activity: Key Insights and Reporting Tips

Anti-Money Laundering, Audit, Blogs, Legal Compliance, Regulatory Compliance, Risk Management / Mark

Teal Compliance explains the signs of suspicious activity in law firm compliance and risk management.

Before I kick off this blog, I’m going to remind you (or explain to you if you are new to the role of an MLRO or COLP) what suspicious activity actually means when it comes to law firm compliance and risk management.

In the context of anti-money laundering (AML) compliance, “suspicious activity” refers to behaviour, transactions, or patterns of conduct that give rise to a suspicion that money laundering or other criminal activity might be taking place.

Persons working in the regulated sector are required under part 7 of the Proceeds of Crime Act 2002 (POCA) and the Terrorism Act 2000, taking into account relevant guidance provided by your regulator, for example the SRA and the Law Society of England and Wales.

If you hold a client account, carry out work in trust and company formation, or offer conveyancing as a legal service, you are more likely to be targeted by financial criminals. Our ASK TEAL service is extremely helpful and supportive for defining suspicious activity, understanding reasonable grounds, inappropriate use, responsibilities of the MLRO / MLCO (depending on size of firm), and the process around reporting economic crime.

To get an idea of the amount of reports submitted, the UK Financial Intelligence Unit (UKFIU) receives over 460,000 SARs per year and stores them in a secure central database.

Before I crack on with more guidance and examples of suspicious activity, here’s a reminder of acronym meanings:

SOW – source of wealth
SOF – source of funds
SAR – suspicious activity report
MLRO – money laundering reporting officer
MLCO – money laundering compliance officer
AML – anti-money laundering
CDD – customer due diligence
DAML – defence against money laundering

This blog is predominantly for the legal profession and we’re kicking it off with Section 12 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (Regulations), Section 12 definition.

AML Guide: Independent legal professionals/trust/company service providers

So, when we’re talking about ‘independent legal professionals’ in these regulations, what we’re really referring to is a firm or a solo lawyer, you know, someone who’s running their own show, providing legal or notarial services to other people. But, and this is important, it’s specifically when they’re involved in financial or property deals.

Think things like:

the buying and selling of real estate and property or business entities;
Management of client money, securities or assets;
the opening or management of bank, savings or securities accounts;
anything to do with setting up, running, or managing a company, when money’s involved; or
the creation, operation or management of trusts, companies, foundations or similar structures.

When you ever read someone that ‘participates’ in a transaction for these rules, what we’re talking about is if they’re helping out with the planning or actually making the transaction happen. Essentially, if they’re acting for the client in some way during the whole thing. It’s about being involved, not just watching from the sidelines.

And then, when we get to ‘trust or company service provider’ that’s a firm who’s running a business and offering these specific services to clients. Now, the key here is, it’s only when we’re actually providing these services that we fall under that definition. So, basically, if I’m providing these services:

forming a firm (The SRA’s definition – forming any entity that, whether or not a legal person, is not an individual and includes a body corporate and a partnership or other unincorporated association)
acting, or arranging for another person to act
- as a director or secretary of a company
- as a partner of a partnership; or
- in a similar capacity in relation to other legal persons;
providing a registered office, business address, correspondence or administrative address or other related services for a company, partnership or any other legal person or legal arrangement;
acting, or arranging for another person to act,
- as a trustee of an express trust or similar legal arrangement;
- or a nominee shareholder for a person other than a company whose securities are listed on a regulated market.

Here’s Section 12’s specifics from source READ HERE.

What is the Definition of Suspicious Activity?

So, what exactly counts as ‘suspicion’ in our line of work?

Well, it’s a lower hurdle than you might think. In the case of R v Da Silva the present standard is set. Lord Justice Longmore said,

“So, probably, ‘knowing’ will not arise and what will arise instead is ‘suspecting’, which is a very different state of mind to knowing. To suspect something, you have a state of mind that is well short of knowing that the matter that you suspect is true. It is an ordinary English word. Members of the jury, if the Crown can show that the defendant said to herself, ‘I suspect that this money is the proceeds of criminal conduct, but it may be, on the other hand, that it is not’, that would fall within the definition of ‘suspicion’. The dictionary definition, which I direct you is relevant to the meaning of the word, is this. The dictionary definition of ‘suspicion’: ‘an act of suspecting, the imagining of something without evidence or on slender evidence, inkling, mistrust’. Therefore, any inkling or fleeting thought that the money being paid into her account 9950 might be the proceeds of criminal conduct will suffice for the offence against her to be proved.”

Essentially, if there’s a possibility, beyond just a far-fetched one, that something’s amiss, you’ve got a reportable suspicion. Of course, a simple ‘gut feeling’ isn’t enough, but if you’re thinking ‘there’s a chance this isn’t right,’ it’s time to take action.

I’m often asked about examples and how far back in the SOF you should be looking at suspicious activity work or actions. The answer is…it depends…because no two clients are the same and no two matters are the same. I’d start by some training on this to begin with, and thereafter have a clear protocol in your policies for firmwide use and follow with proactive controls. Better safe than sorry right?

Suspicious activity may include:

Unusual or inexplicable transactions: Let’s say you’re a conveyancer and your client has passed on admin and payments to a proxy third party. Why? Maybe the purchase price is much higher than current market value. Is your retainer set out £1,000 but they are insistent they’d like to be retained at £10,000? There are a variety of red flags to watch out for here.

Inconsistent behaviour: We would urge you to be on high alert for inconsistent purchaser behaviour in conveyancing or commercial entities. Are they changing key details, are they hard to get hold of, putting off replying to urgent requests? Time to investigate them further!

Deceptive and secretive clients: Got a client that seems evasive? Is the client avoiding questions? Is the client providing incomplete or false information? Why did the client choose your firm?

Exploitation of professional services: You will have been hiding under a rock if you don’t realise that financial criminals target us in the legal services to hide the origins of their illicit funds, i.e. dirty cash. Remember this case of a well paying and long standing corporate client who manipulated their instructing firm and chugged £4.1m through the client account for use of a banking account? The firm was fined £36k by the SRA. Legal Futures article can be read HERE.

A suspicion does not require certainty or concrete proof of money laundering. Instead, it arises when, based on the available information you have, a reasonable person concludes that there is something unusual warranting further investigation.

You’ll no doubt have read the latest cases for firms being fined for breaching AML conditions, like the firm where two partners were fined £50k for offering a banking facility to their wealthy client. In 2023 – 2024 alone, the SRA “submitted 23 SARs, performed 237 proactive inspections, and 258 desk-based reviews, and brought enforcement action against a combined total of 78 firms and individuals.”

This is Teal’s original blog, which has more information to delve into: “AML Definition of Suspicion”

Please note that failure to file a SAR after suspicion is raised is an offence under UK law. You can read the full Law Society guidance HERE.

Key Indicators of Suspicious Activity

The following are some classic examples of what to look out for in terms of red flags.

Unusual Transactions

Large, unexpected deposits with no clear explanation.
Multiple small transactions that together exceed a threshold.
Use of complex legal structures (e.g., trusts, offshore companies) without clear rationale.

Client Behaviour

Reluctance to provide identification or supporting documentation.
Insistence on confidentiality without clear reason.
Clients seeking to use cash for large transactions.

High-Risk Jurisdictions

Funds originating from or being sent to high-risk jurisdictions (e.g., countries known for corruption or weak AML controls)
Keep your “Black and grey” lists pinned to your desktop for continued updates.

Conveyancing and Real Estate

Over or under valuation of property compared to market norms.
Use of funds from unverified sources, particularly cash deposits.

Obligations for Law Firms

Under the AML regime, solicitors and law firms must:

Conduct Customer Due Diligence (CDD): Verify the client’s identity and the source of funds.
Monitor Transactions: Look for unusual patterns or behaviours.
Report Suspicious Activity: File a Suspicious Activity Report (SAR) to the UK Financial Intelligence Unit (FIU) within the National Crime Agency (NCA) if suspicious activity is identified.

Scenarios of Suspicious Activity

Here are some examples that will give you some insights into what and how organised crime can work:

Scenario 1: High-Value Cash Deposit for a Property

A solicitor is instructed by a new client to assist in purchasing a property worth £1.5 million. The client insists on paying £1 million in cash and provides vague explanations for the source of funds. Despite requests for supporting documentation, the client refuses to provide details.

Red Flags: Large cash payment, lack of source-of-funds evidence, and unwillingness to cooperate.

Action: The solicitor would usually file an internal suspicious activity report to their MLRO and then it is the responsibility of the MLRO to decide whether a SAR needs to be made to the NCA.

Scenario 2: Use of Offshore Companies

A client establishes an offshore company and instructs a solicitor to assist with purchasing several properties. The company is registered in a jurisdiction with weak AML controls, and the client is vague about the ultimate beneficial owner (UBO).

Red Flags: Complex structures without legitimate purpose, high-risk jurisdiction, and lack of transparency regarding UBOs.

Action: The solicitor must conduct enhanced due diligence (EDD), request documentation to identify the UBO, and must speak to their MLRO, and then file a SAR if suspicions persist.

Scenario 3: Unusually Structured Payments

Corporate client instructs a law firm to hold funds in a client account as part of a commercial transaction. The funds are received in multiple instalments from unrelated third parties, and the client can’t provide a satisfactory explanation.

Red Flags: Multiple third-party payments, no legitimate business explanation.

Action: Conduct CDD on all parties involved, report to their MLRO, and refuse to proceed if concerns remain, and consider filing a SAR.

Scenario 4: Evasive Client Behaviour

A client seeks advice on setting up a trust but is reluctant to disclose the purpose or the source of the funds. The client requests frequent meetings but provides contradictory information about their income and assets.

Red Flags: Lack of transparency, contradictory information, and attempts to obscure the trust’s purpose.

Action: Ask further questions, verify the information provided, and if suspicions persist, file a SAR.

ALWAYS report suspicious activity to your MLRO come what may.

What triggers a suspicious activity report (SAR) in the UK?

Here’s the deal. There are these laws we have to follow, right? Part 7 of the Proceeds of Crime Act (POCA) and the Terrorism Act. Basically, if you’re working in a regulated field – and that’s us – you have to file a Suspicious Activity Report if you have a sniff that someone’s trying to launder money, evade tax or fund terrorism.

If you, as a law firm, suspects that a client’s SOW or SOF is suspicious, you have to:

Conduct further inquiries to clarify the situation.
Document all findings and decisions.
Consider whether to file a Suspicious Activity Report (SAR).

Reporting Suspicious Activity (SAR)

The above triggers would mean then that you, as an MLRO, or compliance officer, overseeing compliance in your firm should report suspicions straight away to the NCA and SRA (if regulated by the SRA) as follows.

National Crime Agency (NCA):

Yes, as a law firm, you are legally required to report suspicious activity to the NCA via a SAR. The NCA has made this easy to do, as they have a secure SAR portal that you can submit a Suspicious Activity Report.

It shouldn’t surprise you that the SAR portal is SECURE.

Solicitors Regulation Authority (SRA):

While a legal practice has to primarily report suspicious activity to the NCA, it also has obligations to the SRA. Doesn’t everything?!

If the suspicious activity involves a breach of SRA rules or raises concerns about the firm’s compliance, they must report this to the SRA.

Aligning to the SRA’s guidance, you’ve got to report all serious breaches of the money laundering regulations to them. Schedule 4 (12) of the regulations state that supervisors have to collect all information regarding the number of contraventions of these Regulations committed by supervised persons.

A reminder of what constitutes as a Serious Beach

serious or persistent compliance failures involving safeguards designed to prevent money laundering
clear risks of money-laundering activity taking place, or
where there has been potential loss or harm to businesses or individuals.

ASK TEAL is the perfect support solution and service for you, where our compliance consultants and associates are on hand to guide you through your query. Please find out more HERE.

The SRA has its ETHICS HELPLINE to help if unsure: 0370 606 2577

Amy's Reminders and Key Takeaways

Further to the Law Society Risk & Compliance Conference 2025, there is a clear requirement for law firms to conduct better and more robust AML protocols. Don’t rely on a template and not tailor it to your clients and areas of work.

Always conduct thorough CDD and escalate to EDD where necessary.

Please be vigilant about client behaviour, source of funds, and high-risk jurisdictions.

Report suspicions promptly through a SAR, even if it means delaying or refusing a transaction. It’s just not worth the risk.

If there’s one thing I’ve learned in my years working with law and AML, it’s this: meticulous record-keeping is your ultimate defence when demonstrating compliance.

Suspicious Activity Resources Reminder

Proceeds of Crime Act 2002: The primary legislation governing SARs together with the Terrorism Act 2000 (TACT).
Money Laundering Regulations 2017: Sets out AML obligations for law firms. These regs were amended with:
- the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 which came into force on 10 January 2020. This implemented broad changes to the regulations.
- the Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020 made narrow changes mainly to the requirements around trust registration.

When we draft Firm Wide Risk Assessments for clients we also refer to the 2023 amendments which you can read HERE. This amendment was made so that domestic PEPs are treated as lower risk than overseas PEPs, although to be clear, EDD does need to be applied in both instances.

SRA Anti-Money Laundering Guidance: Provides detailed guidance on AML compliance.
NCA SAR Portal: The online platform for filing SARs.

Thanks for reading, and please get in touch with any questions, you know I’m always happy to help.

Amy (with a big dollop of help from Rhiannon!)

SARs – Understanding Suspicious Activity: Key Insights and Reporting Tips Read More »

Risks of Law Firm Client Accounts and why the SRA is concerned January 2024

Risks of Law Firm Client Accounts: Why the SRA is concerned

Audit, Legal Compliance, Regulatory Compliance, Risk Management / Mark

You will have read at the tail-end of 2024 that the Solicitors Regulation Authority (SRA) has raised concerns over the management of client accounts held by law firms, prompting a significant discussion within the legal community.

Amy Bell ran a free, online webinar breaking down the details and giving her tips on how to respond. This took place on 8 January 2025. You can read the comprehensive GUIDE HERE, or you can catch up and watch the session by emailing the team directly at hello@tealcompliance.com.

But why is the SRA so worried about these accounts? The answer lies in the multiple risks associated with them, which range from money laundering and cyber attacks to internal fraud.

Money Laundering Risks

Client accounts have long been seen as attractive targets for money launderers and financial criminals. The government’s national risk assessment has flagged these accounts as potential conduits for illicit money because they allow funds to move through the banking system under the law firm’s name rather than that of the launderer.

What is deemed as “suspicious” when it comes to money laundering?

Suspicious activity use of a law firm’s client account makes it difficult to trace the origins of the funds, thus making law firms inadvertent participants in money laundering schemes.

Just one read of Legal Futures and you’ll hear about the latest fine from the SRA in this regard.

Cyber Attacks and Fraud

Cybersecurity threats also play a significant role in the SRA’s concerns.

Law firms have become targets for cybercriminals who aim to access funds within client accounts.

One common scam, known as “Friday afternoon fraud,” involves hackers intercepting payment instructions and redirecting funds to fraudulent accounts. A classic example of an easy hit for financial criminals, having researched if a legal cashier might be dealing with property transactions late in the day without COFA support.

Despite efforts to combat these schemes, law firms remain vulnerable to sophisticated cyber attacks.

In addition to external threats, internal fraud is another pressing issue. There have been cases where individuals within law firms have managed to manipulate client accounts for personal gain. These internal breaches highlight the importance of robust internal controls and oversight.

High-Profile Failures

Unless you’ve been hiding under a rock, you will be aware that the legal sector has seen some high-profile law firm failures where the misuse of client accounts was a contributing factor. Axiom Ince is the biggest we have all witnessed of course, and the case is still on-going but it has made a significant impact on how the SRA see client accounts and protecting the consumer.

Although not all details of these cases have been made public, the SRA’s concerns are exacerbated by these failures. The misuse of client funds for purposes other than their intended use, such as financing deals, has brought the role of client accounts under greater scrutiny.

The SRA's Response

Given these risks, the SRA has periodically questioned whether solicitors should continue to manage client accounts. This isn’t a new concern; there have been previous efforts to encourage law firms to explore alternatives, such as third-party managed accounts. However, the recent increase in government focus on anti-money laundering (AML) and fraud has added urgency to the discussion.

In conclusion, the SRA’s concerns about client accounts stem from the significant risks they pose to both law firms and their clients. These risks include exposure to money laundering, cyber attacks, and internal fraud, all of which have serious implications for the legal profession. As the debate continues, law firms must remain vigilant in managing these risks and consider whether alternative arrangements might better protect their clients and their business.

Get in touch

We will update you throughout the course of the consultation and thereafter as well.

Please remember that Teal Compliance is your go-to AML and Risk Management Partner and we have a variety of packages available to support you, your colleagues and of course, your clients!

Have a look HERE and we look forward to supporting you soon.

Amy

Risks of Law Firm Client Accounts: Why the SRA is concerned Read More »

Two anonymous people discussing paperwork at a desk

New SRA Notice Warns Against Funds Missing From Client Account

Audit, Legal Compliance, Regulatory Compliance / Rachel Craig

The SRA has published its new Warning Notice (21 June) warns against funds missing from a firm’s client account. The SRA has made it clear shortages will not be tolerated.

Whilst the SRA hasn’t reported any sanctions decisions relating to this issue in particular recently, the warning notice outlines the risks of firms failing to quickly address a shortage.

Firms will note the relatively recent closure of Axiom Ince last year, where the SRA reported the largest shortage in client account funds of £64m.

SRA's Warnings

The SRA’s warnings are as follows:

Firms have an obligation to replace immediately any money missing from a client account
Replacement of funds is to be carried out regardless of the underlying reasons – even where there’s been circumstances beyond the firm’s control for example by way of a cyber-attack, or administrative errors or, dishonest acts by employees
There’s a clear duty in the accounts rules to replace a deficiency, and managers of a firm are jointly responsible for doing so
Firms that continue to transact with a shortfall on their client account risk using other clients’ funds to facilitate those transactions

Employee Behaviour

The SRA provides indicators when identifying behaviour amongst employees that may indicate a problem. This includes failure to deliver bills or a written notification of costs, any suggestion of over-charging, and a sweeping up of residual balances.

Steps To Take

Paul Philip, chief executive at the SRA has said: “Caselaw is very clear that the client account is sacrosanct. However, firms do report shortages on the client account for a variety of reasons. Our rules are also very clear – you must make good on any deficit promptly. A shortage on the client account presents a risk to all clients for whom you hold money.”

Managers are advised to immediately investigate and take action against any member of staff who may have acted dishonestly regarding the client account, and to take regular steps to monitor, review and manage risks
If you identify that money is missing, you have a duty to take steps to ensure it’s replaced, in full, immediately
If you’re a manager of the firm, you have a duty to replace missing client money from your own resources. It may be necessary for you to obtain a loan to do this. It’s irrelevant that fault may not lie with you personally
You need to notify your insurer. You may be able to make a claim on your professional indemnity insurance. The obligation to remedy a breach of the SRA Accounts Rules 2011 is treated as civil liability for the purposes of clause 1 of the Minimum Terms and Conditions
If you identify a shortage, you should report the matter to the SRA in line with your obligations under paragraph 7.7 of the Code of Conduct for Solicitors, RELs and RFLs and paragraph 3.9 of the Code of Conduct for Firms

Enforcement Action

On enforcement action, the SRA warns that failing to replace client money will usually lead to an intervention. Even if money has been replaced, it may be that an intervention is necessary to deal with what caused the problem, such as dishonesty, in order to protect the clients and the public.

Firm Closures

The SRA has also addressed the issue in the context of firms heading for closure, given this can’t happen if there are client balances remaining in a firm’s account.

The SRA has advised any firms seeking to close that they should send all client money to clients, pay counsel fees and bill for outstanding costs.

The notice adds: “If your client account has a shortage, you cannot undertake any of these actions and therefore you cannot close your firm until the shortage is replaced.”

Get in touch

At Teal, we’re here to support your journey towards compliance that works.

We understand that compliance can be a daunting word, but it’s also the key to unlocking your firm’s full potential.

Our experts at Teal Compliance are here to help. Get in touch today to explore tailored solutions and ensure your firm stays ahead of regulatory requirements.

New SRA Notice Warns Against Funds Missing From Client Account Read More »

Is your law firm’s website compliant with the SRA Price Transparency Rules?

Audit, Legal Compliance, Regulatory Compliance / Rachel Craig

If you’re involved in managing compliance at a UK law firm, you’re probably no stranger to the SRA Price Transparency Rules. But just how compliant is your website? In this blog post, we dive into what you need to know and how you can ensure your firm meets the requirements.

Understanding the SRA Price Transparency Rules

The SRA Transparency Rules, which came into force in December 2018, marked a significant shift in how law firms should communicate pricing and service details to their clients. Instructed by the Solicitors Regulation Authority (SRA), these rules aim to improve transparency within the legal sector enabling clients to make informed decisions about their legal matters.

Covering a range of practice areas, law firms must disclose price and service information in a clear and accessible manner. These areas include:

Residential conveyancing
Probate (uncontested)
Motoring offences (summary offences)
Immigration (excluding asylum)
Employment tribunals (unfair/ wrongful dismissal)
Debt recovery (up to £100,000)
Licensing applications (business premises)

Also, it’s crucial to note that even if your firm doesn’t have an online presence through a website, you’re still required to provide this information upon request in alternative formats. This ensures that regardless of the means of communication, clients have access to transparent pricing information.

What the SRA Price Transparency Rules entail

The SRA Price Transparency Rules include a multifaceted approach to transparency and accountability within the legal sector. Beyond the disclosure of pricing and service information, firms have to adhere to additional requirements to enhance clarity and trust. Alongside publishing price and service details, firms must prominently display the SRA’s digital logo on their website, serving as a visual indicator of compliance. This badge reassures clients that the firm operates within regulatory guidelines, instilling confidence in the transparency of legal fees and services offered.

Additionally, the Rules also require firms to publish details of their complaints procedure on their website. This includes comprehensive information on how and when a complaint can be lodged, both to the Legal Ombudsman and directly to the SRA. By offering clear guidance on the complaints process, firms prove a commitment to accountability and client satisfaction.

Teal’s new compliance culture services partnership

As well as ensuring such a damaging and toxic environment doesn’t exist, how can we further test and measure the true culture we have in our workplace?

At Teal we have always believed culture to be the bedrock of sound firm management and compliance. That’s why it’s the biggest, first, and most vital cog in our six Cs of compliance. Without a good culture, the others ‘Cs’ simply won’t work. It’s the foundation from which thriving firms are possible.

That’s why Teal is delighted to be launching its partnership with Gemma Ellison and the team at Heart Leadership.

Gemma said “I started Heart Leadership after spending 15 years in legal practice and so it is a profession I understand and deeply care about. I am committed to helping organisations create healthy and inspiring working environments, which I know, in turn, leads to enhanced wellbeing and higher performing teams. Often, as we move through the ranks of our industry, we are rarely told to fully consider culture and the fundamental impact it has on the working environment of our people. I want to help change that.”

Insights from the Year Three Evaluation

The Year Three Evaluation of the SRA Transparency Rules shed light on the full adoption of the rules. While progress has been made, there are still significant challenges that law firms must address to meet the requirements effectively.

The compliance landscape

According to the evaluation, a majority of firms reported compliance with various aspects of the transparency rules:

75% claimed to provide price and service information
88% displayed the SRA clickable logo
88% published complaints procedures
76% detailed how to complain to the SRA/ Legal Ombudsman

However, when it comes to price and service information specifically, only 42% of firms stated they published all required details. This highlights a significant gap in compliance, with more than half of firms falling short in this crucial area alone.

The reality of compliance

In 2021, the SRA took proactive steps by requiring all law firms with websites to complete a mandatory declaration confirming compliance with the transparency rules. Despite these declarations, spot checks conducted by the SRA revealed a different reality.

Common areas of non-compliance identified during spot checks include:

Partial compliance with certain aspects of the rules, such as publishing price and service information while omitting complaint information
Selective compliance with rules for specific service areas, particularly among firms with multiple websites or sections dedicated to different areas of law
Incomplete publication of information regarding how services will be delivered and by whom
Improper display of the SRA clickable logo, hindering the dynamic link to firm information on the SRA website

Ensuring compliance

Ensuring compliance with SRA Price Transparency Rules is essential for law firms to maintain trust and transparency with their clients, as well as meet their regulatory requirements.

So, how can your law firm ensure compliance with the transparency rules?

1. Review your website regularly

Regularly review your website to ensure all required information is up-to-date, accurate, and easily accessible to visitors. Keeping a vigilant eye on your online presence ensures that potential clients can find the information they need without any hassle.

2. Utilise SRA templates

Take advantage of the SRA’s provided templates for suggested text. These templates can be invaluable in identifying any missing information on your website, helping you align with the requirements of the Transparency Rules more effectively.

3. Consider user experience

Prioritise the user experience on your website to ensure that clients can easily navigate and find the necessary information. Whether through specific webpages, intuitive online quote tools, or seamless connections to price comparison sites, prioritising accessibility enhances client satisfaction.

4. Get expert help

If you’re unsure about compliance or need assistance, Teal Compliance offers website audit services. We can provide guidance and help you navigate any non-compliance issues, ensuring your firm remains aligned with regulatory standards.

Moving forward

The findings highlight the importance of ongoing vigilance and proactive measures to achieve full compliance with the SRA Transparency Rules. Law firms must not only ensure that they are meeting the minimum requirements but also strive for transparency and clarity across all aspects of their online presence.

As regulatory scrutiny intensifies and expectations evolve, firms need to review their compliance strategies, address identified gaps, and embrace best practices to uphold the principles of transparency and accountability.

Get in touch

At Teal, we’re here to support your journey towards compliance that works.

We understand that compliance can be a daunting word, but it’s also the key to unlocking your firm’s full potential.

Our experts at Teal Compliance are here to help. Get in touch today to explore tailored solutions and ensure your firm stays ahead of regulatory requirements.

Is your law firm’s website compliant with the SRA Price Transparency Rules? Read More »

Laptop with the Teal Tracker's Root Cause Analysis Process on screen

The Teal Tracker’s New Feature: Root Cause Analysis Process

Audit, Blogs, Legal Compliance, Risk Management / Joanne

The Teal ‘Root Cause Analysis Process’, or ‘RCAP’, is a new, groundbreaking feature of the Teal Tracker. Here we explain what it does, how it works and how it can benefit you.

What does the Root Cause Analysis Process do?

The Root Cause Analysis Process forms part of the Incident Management module in the Teal Tracker, and is a yet another example of how law firms can use their compliance data to help reduce the future risk of claims, complaints and breaches.

At its core, it assists in identifying trends and reducing incidents through identification, analysis and learning, which will in turn protect clients, the firm and the team.

How does the Root Cause Analysis Process work, and how is AI involved?

The RCAP feature uses AI to assist firms in identifying root causes of issues or near misses. It forms part of the Teal Tracker’s Incident Management module, whereby firms can analyse incidents to drill down to root cause.

As with all our new features in the Teal Tracker, we’ve extensively asked our law firm partners how they would best like to see this work in practice, so its design is simple and intuitive.

Teal Tracker subscribers are invited to carry out a Root Cause Analysis Process using the ‘five whys’ methodology principle, which is a standard engineering concept developed way back in the 1950’s for Toyota’s production line. It is, at its core, really simple. The principle is that if you ask ‘why’ something went wrong five times, you’ll likely drill down to arrive at the core answer.

But the Teal RCAP combines this tried and tested practice with AI to generate the next response to each of the ‘five whys’ questions and to confirm the root causes and their weightings. This smartly assists users in drilling to the key root cause or causes, and skillfully assists law firms in getting to the true root cause and the granular detail of issues.

This is then automatically exported to the Teal Tracker’s management reports functionality. In turn, this allows trend analysis to be systematically identified in detail, and reflected back to the firm to ensure they can both learn and improve in the key areas they really need to focus on.

Why has Teal integrated AI into the Root Cause Analysis Process?

Teal has integrated generative AI into the solution so that AI can smartly create the next drill down question to ultimately display what has actually happened and its cause. This means users have smart options to drill down into the issues and figure out what precisely occurred and what contributed to each particular problem.

It will give the firm much more useful and intelligent data on which to make decisions or to deploy resource. This will assist in better use of budgets for training or capacity as well as ultimately reducing the number of claims, complaints and breaches that occur.

How is the Root Cause Analysis Process working in practice?

Teal has been trialling the solution in full, in live environments for some time and it’s working extremely well. That’s why we’re now proud to be able to roll-out this groundbreaking feature to all our Teal Tracker law firm partners.

Want to know more about the Teal Tracker?

At Teal, we’re here to support your journey towards compliance that works. Our compliance technology platform, Teal Tracker, is the solution to your compliance issues, ensuring you, your firm and your clients are safe.

To find out more about the Teal Tracker, or to book a demo, contact our team today!

The Teal Tracker’s New Feature: Root Cause Analysis Process Read More »

Business women at desk meeting with laptop and notepad

Legal compliance issues: Embracing legal compliance for success

Audit, Blogs, Legal Compliance / Joanne

In the world of law firms, the mere mention of the “C” word tends to send shivers down the spines of many. Partners and owners alike sometimes choose to bury their heads in the sand, hoping that legal compliance issues will resolve themselves. However, the landscape is changing rapidly, and firms are evolving their approaches to business support. The old misconceptions of ‘fee burners’ and ‘fee earners’ are giving way to a proactive stance, where compliance isn’t just a requirement but a fundamental aspect of a firm’s culture.

We believe that investing in business support is the compass that points your firm in the right direction. In this blog post, we’ll delve into why legal compliance is the cornerstone of your firm’s success. It’s not just about collecting a plethora of accreditations, although staying within the guidelines of these accreditations certainly minimises your risk exposure.

Asking the right questions and breaking down silos

Are you asking the right questions to stay informed about your firm’s day-to-day activities? Are all departments collaborating to review risk registers and ensure everyone’s on the same page? Avoid the smoke and mirrors approach, which only masks underlying legal compliance issues. Instead, let’s shine a light on the importance of communication.

Engaging with your employees is key to success. Often, during performance reviews, employees express a lack of communication. It’s not about inundating your team with every minor detail; it’s about involving them in achieving the firm’s objectives. Without effective communication, there’s room for important matters to slip through the cracks.

Consider a compliance project. How many different team members are involved, and is there a streamlined approach to ensure continuity and prevent duplicate tasks? A joined-up approach is crucial.

Ground-level knowledge: Your shield against regulatory pitfalls

Ground-level knowledge is your shield against regulatory pitfalls. To truly understand its importance, think of it as a solid foundation based on understanding, vigilance, and adaptability. In this section, we’ll explore why this knowledge is crucial for the well-being and prosperity of your law firm.

1. A foundation of understanding

Understanding begins with actively listening to what’s happening within your firm. It means having a finger on the pulse of daily operations, being aware of the challenges your employees encounter, and comprehending the intricacies of your clients’ needs. This understanding extends to the beliefs and values that underpin your firm’s culture, ensuring everyone is aligned with the same vision.

2. The cost of ignorance

When it comes to legal compliance issues, ignorance is not a valid defence. Regulators expect firms to be well-versed in the regulations governing their sector, and they won’t accept ignorance as an excuse for non-compliance.

Ignorance can lead to dire consequences, including hefty fines, damage to your firm’s reputation, and even legal repercussions. In the eyes of the law, not knowing isn’t an excuse. Ground-level knowledge is your safeguard against such risks, as it empowers you to stay informed and take proactive measures to address potential legal compliance issues.

3. The power of continuous review and analysis

Ground-level knowledge isn’t a static state but an ongoing process. It involves continuously reviewing your firm’s processes and critically analysing essential data.

Regular process reviews enable you to identify bottlenecks, inefficiencies, or areas where compliance may be at risk. It’s similar to fixing weaknesses to make sure they can handle the challenges of time and close inspection. Additionally, the analysis of critical data allows you to spot emerging trends and potential compliance challenges before they escalate into formidable problems.

Conducting a full 360 review of your business

The process of conducting a full 360 degree review of your law firm isn’t just a routine task; it’s a transformative journey that aligns your firm with the ever-evolving regulatory landscape. Visualise it as the compass that directs your firm towards its full potential in legal compliance. In this section, we’ll delve into why this comprehensive examination of your business is vital for your law firm’s success, particularly in the context of legal compliance, and how it can lead to meaningful change.

1. Celebrating achievements and strengths

Every law firm possesses unique achievements and strengths, often concealed in plain sight. Taking the time to recognise and celebrate these successes isn’t just about acknowledging your accomplishments in legal compliance; it’s about honouring what’s working exceptionally well within your compliance framework. These are the foundations upon which you can build a robust legal compliance structure for the future.

2. Embracing a culture of self-scrutiny

Genuine growth often necessitates introspection. It involves the willingness to roll up your sleeves and delve deep into the areas of legal compliance that require improvement. Just as a sculptor chisels away at a block of marble to reveal a masterpiece, your firm must be prepared to examine the rough edges within your compliance procedures.

Scrutinising areas that need improvement isn’t a sign of weakness; it’s a testament to your dedication to legal compliance. It’s about identifying bottlenecks, inefficiencies, or outdated practices that may pose legal compliance issues. This process demands honesty and the willingness to address shortcomings proactively.

3. Implementing systematic change

The true power lies in translating your observations and insights into systematic changes that enhance legal compliance. Instead of just pinpointing issues, you develop actionable solutions that bolster your compliance efforts. These changes may include streamlining compliance processes, investing in training and development for your compliance team, or adopting new technologies to bolster compliance tracking and reporting.

This proactive approach creates an environment where your team can excel in legal compliance, your clients receive a top-notch service, and your firm operates with the utmost legal compliance diligence.

Revisiting key performance indicators (KPIs)

Key Performance Indicators, or KPIs, are not confined solely to your fee earners. They’re a potent tool that can revolutionise your firm’s approach to maintaining compliance standards. In this section, we’ll explore why KPIs are indispensable, how they extend beyond the fee earners, and why regular reviews are essential to ensure they align with your legal compliance objectives.

1. Expanding the scope of KPIs in legal compliance

While fee earners often take the spotlight, KPIs have a more profound role to play in the broader context of legal compliance. They should encompass every facet of your firm’s operations, from risk management to client service and regulatory adherence. By embracing a holistic perspective, you can foster a culture of compliance that permeates every department.

KPIs that focus on legal compliance go beyond mere metrics; they become a compass guiding your firm towards a safer, more compliant working environment. They encourage proactive behaviours and decision-making that prioritises adherence to regulations, mitigating risks, and ensuring ethical conduct.

2. The imperative of regular KPI reviews for legal compliance

KPIs are not static; they should evolve to reflect changing compliance requirements and your firm’s objectives. Regular reviews are the lifeblood of effective KPI implementation in legal compliance.

During these reviews, you assess whether the KPIs are still relevant, achievable, and aligned with your evolving legal compliance goals. They provide the opportunity to recalibrate your firm’s course, ensuring that you continue to navigate the legal compliance landscape with precision.

Independent file audits: Elevating legal compliance through insightful evaluation

Consider conducting independent file audits. They can unveil trends that highlight training issues or identify individuals with untapped potential. Striking a balance between micro-management and providing adequate supervision is essential for responsible leadership.

Conducting independent file audits is a strategic manoeuvre that transcends routine checks; it’s an opportunity to gain unparalleled insights and elevate your firm’s commitment to legal compliance. In this section, we’ll explore why independent file audits are a linchpin in the quest for legal compliance excellence, how they unearth invaluable trends, and their pivotal role in honing the skills of your team.

1. The power of independent file audits in legal compliance

Independent file audits are not mere paperwork exercises; they’re powerful tools for enhancing legal compliance. These audits provide an unbiased lens through which you can scrutinise your firm’s practices, ensuring they align with regulatory requirements and best practices. Beyond the checkboxes, they offer a holistic view of your firm’s performance in legal compliance.

One of the key advantages of independent file audits is their ability to spot trends. These audits can unearth patterns that might otherwise remain hidden. For example, they can highlight recurring legal compliance issues or training gaps within your team. By identifying these trends early, you can proactively address them, fortifying your legal compliance framework.

2. Enhancing training and identifying potential

The insights gained from independent file audits extend beyond compliance issues. They can also help identify individuals within your team who possess untapped potential. By recognising standout performance, you can nurture future leaders or identify team members ready for greater responsibilities. This not only benefits your firm’s growth but also bolsters its commitment to legal compliance, by having capable leaders.

3. Striking the balance in legal compliance leadership

Achieving legal compliance excellence requires a delicate balance between oversight and empowerment. Micro-management stifles initiative, while inadequate supervision can lead to lapses in compliance. Independent file audits help strike this balance. They provide a mechanism for oversight without suffocating your team’s autonomy.

Every role matters: A unified framework

In compliance, the significance of every role within your firm can’t be overstated. It’s not just the lawyers or compliance officers; it’s every individual, from support staff to partners. Embracing a unified framework is the cornerstone of fostering compliance excellence. In this section, we’ll emphasise the importance of this cohesion where everyone comprehends their responsibilities, and how it results in tangible benefits for your firm.

1. The power of a unified framework in legal compliance

Legal compliance isn’t a responsibility that falls solely on the shoulders of a select few; it’s a collective effort. Encouraging your entire team to work within an established framework ensures that legal compliance becomes an integral part of your firm’s DNA. This framework provides clarity, defining roles, expectations, and the processes that ensure adherence to regulatory requirements.

2. Benefits of cohesion in legal compliance

When every team member understands their role within the legal compliance framework, several benefits emerge. First, it minimises the risk of compliance gaps or oversights. Second, it fosters a culture of accountability, where everyone takes ownership of their compliance-related duties. Third, it streamlines communication and collaboration, facilitating smoother compliance processes.

In addition, a unified approach to legal compliance enhances your firm’s reputation. Clients and regulatory bodies, such as the SRA, perceive your organisation as one that takes its responsibilities seriously, instilling trust and confidence. It also mitigates potential legal risks, reducing the likelihood of legal repercussions or fines.

Get in touch

At Teal Compliance, we’re here to support your journey towards compliance that works by mitigating the risk of legal compliance issues.

We understand that compliance can be a daunting word, but it’s also the key to unlocking your firm’s full potential. Don’t hesitate to reach out if you need assistance. Together, we can navigate the compliance maze and ensure your firm’s continued success.

Legal compliance issues: Embracing legal compliance for success Read More »

Audit

Money Laundering’s Slow Burn

Law Firm AML Complacency, Culture and Drift

Regulatory Guidance and Enforcement

Time to Jump out of the Boiling Pot?

Make it Safe to Talk - Risk Management Tip No. 1

Promote Practical Wellbeing Strategies for High-Pressure Tasks - Risk Management Tip No. 2

Lead by Example - Risk Management Tip No. 3

Empower with Knowledge - Risk Management Tip No. 4

Regulation 21 and Independent Audits

Introduction to Ongoing Monitoring

Defining Ongoing Monitoring

SRA Guidance on Ongoing Monitoring

Challenges in implementing ongoing monitoring

Three point ongoing monitoring guidance

Beginning stage: file opening

Middle stage – review of CDD documents

End stage – last minute changes

Practical Guidance on Risk Assessment Frequency

Challenges in Implementing Ongoing Monitoring

Contents

Understanding beneficial ownership

Definition of an individual PSC of a UK company

Definition of a beneficial owner of an overseas entity

Examples of concealing beneficial ownership

Don’t rely on the corporate veil — lift it

Challenge vague answers

Document the risk rationale

Verify control, not just ownership

Watch for layered structures

US Legislation News For Information

AML Guide: Independent legal professionals/trust/company service providers

What is the Definition of Suspicious Activity?

Suspicious activity may include:

Key Indicators of Suspicious Activity

Unusual Transactions

Client Behaviour

High-Risk Jurisdictions

Conveyancing and Real Estate

Obligations for Law Firms

Scenarios of Suspicious Activity

Scenario 1: High-Value Cash Deposit for a Property

Scenario 2: Use of Offshore Companies

Scenario 3: Unusually Structured Payments

Scenario 4: Evasive Client Behaviour

What triggers a suspicious activity report (SAR) in the UK?

Reporting Suspicious Activity (SAR)

National Crime Agency (NCA):

Solicitors Regulation Authority (SRA):

Amy's Reminders and Key Takeaways

Suspicious Activity Resources Reminder

Money Laundering Risks

Cyber Attacks and Fraud

High-Profile Failures

The SRA's Response

Get in touch

SRA's Warnings

Employee Behaviour

Steps To Take

Enforcement Action

Firm Closures

Get in touch

Understanding the SRA Price Transparency Rules

What the SRA Price Transparency Rules entail

Teal’s new compliance culture services partnership

Insights from the Year Three Evaluation

The compliance landscape

The reality of compliance

Ensuring compliance

1. Review your website regularly

2. Utilise SRA templates

3. Consider user experience

4. Get expert help

Moving forward

Get in touch

What does the Root Cause Analysis Process do?

How does the Root Cause Analysis Process work, and how is AI involved?

Why has Teal integrated AI into the Root Cause Analysis Process?

How is the Root Cause Analysis Process working in practice?

Want to know more about the Teal Tracker?