It’s no secret that conveyancers have found themselves in the crosshairs of the Solicitors Regulation Authority (SRA) recently. We have seen a raft of fines handed down over the past few months making it crystal clear to us that anti-money laundering (AML) compliance isn’t a ‘back-office’ administrative concern, it’s a front-line regulatory risk.
The team and I here at Teal Compliance have been concerned for some time that conveyancers were becoming a key focus for regulators as their work sits at a crossroads of complexity, urgency and high financial value. Add the stress of Stamp Duty changes, market fluctuations, recruitment hassles and tech onboarding, that makes the sector vulnerable to exploitation by economic criminals and criticism from the regulator for even minor missteps.
So when Today’s Conveyancer recently reported that conveyancers are bearing the brunt of recent AML sanctions it was a loud wake-up call to the profession.
A pattern of fines, a pattern of risk
Let’s take a look at just a few recent enforcement actions by the SRA:
- Cooklaw Solicitors Ltd was hit with a £25,000 fine, the maximum the SRA can currently impose without a tribunal, for having no firm-wide risk assessment (FWRA), no evidence of client due diligence on eight out of ten conveyancing files reviewed, and for failing to apply enhanced due diligence when the situation clearly demanded it.
- Stapletons Solicitors LLP was fined £9,767 after failing to produce any firm-wide risk assessment during an SRA inspection. Perhaps most concerning, they had no client or matter risk assessments on nearly half their conveyancing matters and failed to verify the source of £770,000 paid into their client account.
- HSR Law Limited was fined £23,549 in June 2025 for having AML policies, controls, and procedures (PCPs) on paper but not actually using them. They had a CMRA template, but none of the six files reviewed contained a completed CMRA.
- Nexus Solicitors Limited was fined £31,217 by the SRA in February 2025 for failing to carry out client and matter risk assessments (CMRAs) on multiple conveyancing files over a six-year period. Although the firm had AML policies and templates in place, it didn’t use them in practice, and no completed risk assessments were found on any of the six files reviewed. The SRA noted that this showed a long-term failure to comply with statutory AML obligations.
Each case paints a similar picture. The issue is rarely one of wilful misconduct. These are not cases involving money laundering itself, but rather failures of process, documentation, and leadership. The SRA is making it clear that good intentions are not enough, and in their own words, firms that fall short “risk facilitating dubious transactions.”
Why conveyancers are particularly vulnerable
Conveyancing teams are often under relentless pressure: tight deadlines, demanding clients and increasing caseloads. Add in the cost-of-living crisis and ongoing staffing shortages, and it’s no surprise that compliance sometimes gets pushed down the to-do list.
But the problem is this: AML compliance can’t wait until after exchange. It must be embedded in every client interaction from day one. That means properly documented CDD, matter risk assessments, checks on the source (and sometimes the source of the source) of funds, and a team that knows what to look for.
This is especially true now that the SRA has adopted a tougher approach to financial penalties. The days of token fines are behind us. Firms are being held to account not just for what they failed to do, but for the systems and culture that allowed those failures to go unchecked.
The Axiom Ince effect
This regulatory pressure isn’t happening in a vacuum. The SRA is under scrutiny too, particularly in the wake of the Axiom Ince scandal, where more than £60 million of client money was reportedly misappropriated. In response, the Legal Services Board issued directions to the SRA, requiring them to overhaul how they supervise firms and enforce compliance.
As part of that response, the Directions Implementation Action Plan, published in July, confirms that the SRA will now be proactively intervening where there is a pattern of risk and will be expanding thematic reviews (especially in high-risk practice areas like conveyancing).
We’re already seeing the impact. AML is no longer just an audit question. It is a reputational issue and a regulatory tripwire.
What effective compliance looks like in practice
From our experience working with conveyancing firms of all sizes, the challenges are consistent – but so are the opportunities to get ahead of the regulator’s expectations.
Here are a few anonymised examples of good practice we’ve observed:
- Case study A: The risk assessment wake-up call
A mid-sized high street firm discovered during an internal compliance review that their firm-wide risk assessment hadn’t been updated in over two years. It no longer reflected their client profile or areas of risk. The firm brought compliance, risk and legal teams together to redraft the FWRA, ensuring alignment with LSAG guidance and current SRA expectations. - Case study B: From templates to practice
A residential property team had CMRA templates in their systems, but they weren’t being completed or reviewed consistently. A deeper dive revealed that staff lacked confidence in assessing different types of risk. After tailored training and the addition of clear guidance notes and worked examples, usage rates and the quality of assessments improved dramatically. - Case study C: SoF and SoW in real life
One firm working with a growing number of overseas investors found that its staff were conflating source of funds (the immediate bank account) with source of wealth (the origin of that money). By clarifying definitions in their internal guidance and providing decision trees for escalation, the team reduced uncertainty and improved the defensibility of their due diligence processes.
These examples aren’t about achieving perfection. They’re about building momentum. The firms that stay out of the regulator’s sights are usually those that treat compliance not as an annual exercise, but as a lived, daily part of their practice culture.
Don’t wait for a knock at the door
The firms fined this year likely never thought they’d be on the SRA’s radar. But as we’ve seen, it doesn’t take a smoking gun, just a missed form, a forgotten assessment, or an unchallenged payment.
The best time to review your AML compliance was yesterday. The second-best time is today!
Eilish Cullen is a regulatory compliance, GDPR, AML & CQS specialist at Teal Compliance
