[1]AML: Number of SRA fines has slowed down
The Solicitors Regulation Authority (SRA) has fined 59 law firms a total of £600,000 in the past six months for breaching basic anti-money laundering (AML) rules.
Three of the firms – Scunthorpe-based BRR Law, London-based William Heath & Co and Bicester-based HMG Law – were fined £25,000, the maximum amount that the SRA can impose on traditional law firms.
Across all 59 firms, the common failures were not having a firm-wide risk assessment and/or policies in place, inadequate controls and procedures to mitigate and manage effectively the risks of money laundering and terrorist financing, and not undertaking client and matter risk assessments (CMRAs).
The regulator has issued a steady stream of fines in recent years to firms that failed to show how they have complied with the 2017 Money Laundering Regulations during SRA investigations.
But these latest figures revealed a notable drop in the number of firms being fined during the last nine months.
In the three months between September and November 2025, when we last reported on AML fines [2], the SRA fined 46 firms a total of £550,000.
The average size of the fines fell too, down from £12,000 per firm in that period, to £10,000 in the past six months.
The money collected goes to HM Treasury.
For the three firms fined £25,000 each, the penalties could have been far higher. Under the SRA’s guidance, fines for breaches of AML rules are based on a firm’s annual turnover.
For HMG Law, which was acquired by RWK Goodman in January four days before it reached an agreement with the SRA on its AML breach, the fine should have been £27,901. William Heath & Co’s should have been £31,152 and BRR Law’s £36,200.
In all three cases, the SRA reduced the penalty to £25,000 rather than refer the cases to the Solicitors Disciplinary Tribunal, because none of the firms “appear to have made any financial gain or received any other benefit as a result of its conduct.”
HMG failed to keep an up-to-date written records of its assessments of the risks of money laundering and terrorist financing, failed to review and update its policies, controls and procedures, and failed to conduct CMRAs.
An inspection of six William Heath & Co files revealed that none contained a CMRA. In four, the firm also failed to scrutinise client transactions or the source of funds. The SRA recommended that its fee-earners should receive training on source of funds checks.
With BRR, there was an eight-year failure to conduct CMRAs. This “translated to a poor understanding of the risks posed by clients and matters and resulted in insufficient scrutiny being applied”, the SRA said.
A Legal Futures investigation [3] last year highlighted how many of the firms fined for AML breaches are members of the Law Society’s Conveyancing Quality Scheme (CQS) and/or Lexcel scheme, raising questions about how rigorously the standards – which both require AML compliance – are policed.
Of the 59 firms fined in the past six months, 53 (90%) were members of the CQS and three carried the Lexcel accreditation.
Writing recently on LinkedIn [4], Brian Rogers, regulatory director at The Access Group’s legal division, warned that CQS accreditation would become an “aggravating factor” in cases when the Financial Conduct Authority took over as the supervisor of lawyers’ AML activity.
Mr Rogers predicted the FCA will fine CQS-accredited firms more for giving clients “false assurances.”
He said: “The SRA’s approach — modest fines, settlement agreements, published outcomes — is designed to encourage compliance through transparency. The FCA’s approach is designed to ensure compliance through consequence.
“The two are not the same. Firms that have spent years navigating the SRA’s relatively accommodating enforcement posture may find the adjustment significant.
“The quality mark that was supposed to protect you may, under the FCA, be the thing that costs you most.”