Money Laundering Procedures Sanctions

It appears that law firms and the individual solicitor appointed to be the Money Laundering Reporting Officer (MLRO) face substantial penalties if they fail to maintain the required anti-money laundering procedures.  A case in point took place recently in England, as reported in the Law society’s Gazette 6^th November 2008, when the financial advisory firm of Sindicatum Holdings was fined £49,000 and it’s MLRO, Michael Wheelhouse, was fined £17,500 for not having adequate systems in place.  The FSA stated that there was a failure to take reasonable steps to implement adequate procedures for controlling money laundering risk.  There was no evidence that any actual money laundering had taken place.  It was simply that the clerical procedures were not apparent.  This is likely to be a significant risk to practitioners.  After all, why would anyone incur the risks and frustrations of pursuing real criminals when this lucrative option is available?