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Risk assessment6 min read

Why generic firm-wide risk assessments create SRA risk

One of the most common issues the SRA finds is reliance on generic or template-based firm-wide risk assessments that don't reflect the firm's actual risk profile. The expectation is a genuinely risk-based AML framework — not a compliance document that could belong to any firm.

Here's why generic FWRAs attract attention, and what a credible one looks like.

It doesn't reflect your firm

A template can't capture your specific clients, services, jurisdictions, and delivery methods. When the FWRA doesn't match the firm's actual risk profile, it signals that risk hasn't really been assessed — and the rest of the framework rests on a weak foundation.

It goes out of date

The SRA frequently finds FWRAs that aren't updated to reflect changes in clients, services, jurisdictions, or delivery methods. A risk assessment is a living document; if your practice has changed and the assessment hasn't, that gap will show.

It contradicts your controls and files

A key concern is inconsistency between the FWRA, day-to-day controls, policies, and client files. If the assessment says one thing and the files show another, the firm can't evidence that its framework actually works in practice.

What a credible FWRA looks like

  • Specific to your clients, services, jurisdictions, and delivery methods
  • Updated as the firm's risk profile changes, with version history
  • Linked to the policies and controls meant to mitigate each risk
  • Consistent with matter-level risk assessments and files

Reglo helps firms keep this evidence organised and audit-ready — humans approve every change. AI drafts and organises; your compliance team decides.

This guide is general information for compliance teams, not legal or regulatory advice. Always refer to the SRA's current guidance and take your own professional advice where needed.

Common questions

How often should we update the firm-wide risk assessment?

Whenever the firm's risk profile changes — new client types, services, jurisdictions, or delivery methods — and reviewed regularly besides.

See how Reglo keeps this evidence ready

Book a demo and we'll show you how Reglo keeps your policies, training, attestations, and audit-ready evidence aligned for SRA reviews — with humans approving every change.

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