Despite being a requirement under the Money Laundering Regulations 2017 (MLR 2017), in 2023/24 the SRA found that 19% of files reviewed did not contain a client and matter risk assessment (CMRA), with a further 12% of files containing ineffective CMRAs.

At best, the firms conducting these files were putting themselves at risk of regulatory action for failure to comply with the MLR 2017. More seriously, firms may have been facilitating money laundering through their failure to adequately assess and address the risks posed by clients and matters.

The SRA has issued a number of significant fines to firms with no, or insufficient, CMRAs in place. In the year August 2024 to July 2025, firms were fined over £950,000 where ineffective or missing CMRAs were noted.

Although a firm’s MLRO, MLCO or its managers bear ultimate responsibility for ensuring its compliance with the MLR 2017, it is the responsibility of all those working on behalf of the firm to conduct and document the appropriate processes and checks on a day-to-day basis. Therefore, it is imperative that all staff understand not only how to complete a CMRA, but also the importance of doing so thoroughly and correctly.

This course will assist fee earners and support staff in confidently and competently completing client and matter risk assessments, understanding the types of risks to be identified and the importance of correctly identifying these.