East Anglia based law firm Clapham & Collinge Solicitors has been established for over 65 years and provides a full range of legal services to businesses and individuals across Norfolk.
Soon after the start of the pandemic in 2020, when remote working was enforced, the Clapham & Collinge team sought an independent review of their policies, procedures and processes. Risk management consultancy Legal Eye was the perfect choice.
Starting with the foundations
Mark Kermez, Managing Partner and Head of Litigation and at Clapham & Collinge LLP, enlisted the assistance of Susan Faulkner, Head of Risk and Compliance at Legal Eye, and in June of 2020, Susan began working with Mark and the senior management team in a remote capacity to review various documents through a Risk and Compliance Gap Analysis.
Once the gaps were identified, changes were suggested in order to improve the firm’s policies and procedures, to ensure they were up to date, that the AML regulations were being complied with across all practice areas (and evidence documented), and that GDPR and other data protection regulations were being adhered to.
Susan delivered a full compliance report to Mark and his team, setting out a risk management plan to ensure regulatory compliance.
Just like many other law firms, the team at Clapham & Collinge LLP had been navigating their way through the disruption caused by the covid-19 pandemic, various lockdowns, SDLT holidays and managing remote working; all of which increased the burden of compliance on fee-earners across all departments. In September they received a letter from the Solicitors Regulation Authority (SRA) informing them that the SRA will be conducting a thematic review of all law firms in the area. Clapham & Collinge once again called upon the Legal Eye team to support them in preparing for the upcoming SRA visit.
The visit was booked for December and, as most firms will be aware, AML documents need to be provided 21 days prior to the visit.
Susan conducted a review of the firm’s AML processes by looking through all of the AML policies and documentation held. This included looking things like Source of Funds methodology and Matter Risk Assessments.
Susan then worked with the team to pull together all of the necessary materials and documents to send to the SRA. There was sufficient time during the three months prior to submitting the documents to get everything in order. This was helped too by virtue of the fact that as the firm’s COLP and MLRO, Mark was in a good position to work closely with Susan and the other consultants.
Susan comments: “A good level of two-way cooperation and collaboration is really important to us when working with clients and it was brilliant to have Mark work so closely with us, actioning and implementing everything we recommended in a timely manner. All too often we see firms struggling to embed into their culture the need to keep reviewing and mitigating any potential gaps in their processes. Clapham & Collinge are a great example of what can be achieved when a firm chooses to take a systematic approach to risk and compliance.”
The firm also uses Legal Eye’s Training Academy – on online training platform offering a range of modules covering core risk and compliance topics. As well as providing a convenient and cost-effective platform for firms to train their staff, it also assists in keeping records of who has completed training – including refresher training – and records the scores of the quizzes which are undertaken at the end of each module to check understanding.
Preparing for the visit
Susan wrote up her findings including guidance notes so that Mark and the board could put into place all of the findings and prepare for the regulator’s visit.
Susan also conducted mock interviews with key members of staff, following this up with another set of file reviews to ensure everything was in place in good time and, more importantly, that the correct approach was truly entrenched within the firm and part of the everyday working practices across all teams.
On the day?
Mark’s comments say it all: “The day went really well; the interview with me was really positive, and the SRA representative was impressed with my colleague’s level of knowledge and understanding.
“Thank you once again for all of your help and assistance with this – it’s been absolutely brilliant to have you and the team on board and has made all the difference to our processes and my understanding of the obligations.’’