Compliance activity surrounding the 2017 Criminal Contract has picked up pace in recent weeks. Duty Solicitor compliance has been to the fore but office requirements (especially new ones) have also been under scrutiny, including Contract Managers acting as Secret Squirrel or perhaps Inch High Private Eye and making unannounced visits.
To deal with office requirements first the 2 key sections, and likely areas of friction, are here, they will push hard on every element of 2.44. Serviced offices have proved the most common problem so watch for signage and the reception function.
With regard to Duty Solicitors they are considering all requirements and elements of the CRM 12, COLP declaration. We have experienced pretty much the full range of issues however, and unsurprisingly, the ill-defined 14-hour rule has proved the most common and controversial. Equally predictably, audit activity has proved patchy and inconsistent; obvious local ghost have been ignored whilst ostensibly compliant firms given the “Spanish inquisition”.
At this stage I don’t want to communicate too much on audit practice in public, due to ongoing cases, cases which might result in some clarification if nothing else. Also we have many firms who benefit from a light audit approach which doesn’t target obvious non-ghosts. Be under no illusion however some of our experience is at the extreme, Termination Notice, end of the scale.
Others have required a very great deal of hard, retrospective, evidence production to close out. The watchword is therefore good contemporaneous record keeping, you will not find a better template than the one Crimeline have generated. The production of clear, comprehensive compliance records will almost certainly help you avoid any secondary and more detailed assessment.
Bigger problems, you might want to give us a ring.
UPDATE
Here is the LAA take on what is going down (as the kids might say)
