The latest round of Solicitors Regulation Authority (SRA) penalties for AML breaches includes firms of all sizes, from Legal 500 companies to small high street outfits. With a high percentage of their work coming from conveyancing, the SRA views each as being at high risk of exploitation from criminals.
Bristol-based Humphreys & Co reached a regulatory settlement agreement with the SRA to the tune of £24,922 following a review by the AML proactive supervision team. Between 26 June 2017 and 30 June 2022, the firm failed to establish and maintain fully compliant policies, controls and procedures (PCPs). The SRA said that in six of the eight files reviewed, the firm failed to maintain records of its client and matter risk assessment (CMRA).
Regarding the high fine, the SRA said that although the firm put in place compliant PCPs prior to their inspection and a compliant CMRA process in June 2022, CMRAs were not being “sufficiently recorded consistently”, demonstrating a “persistent disregard” for its regulatory obligations.
The SRA noted that the firm took steps to rectify its failures and implemented compliant PCPs before and since its inspection, and has ensured that all files in scope of the MLRs 2017 include a completed CMRA. A fifth of the firm’s turnover comes from conveyancing work.
Castle Sanderson Limited in Leeds was fined £10,462 for failing to regularly review and update its PCPs between 26 June 2017 and 27 May 2025. The SRA also found that in 34 files, the firm failed to conduct CMRAs. Around 75% of the firm’s work is in conveyancing.
A financial penalty towards the lower end of the bracket was agreed because, despite the lack of compliance until May 2025, the SRA said it was pleased to see the firm has now put in place compliant PCPs, rolled out training to staff on obtaining, documenting and scrutinising source of funds (SoF) checks and completing and documenting CMRAs, reviewed live in-scope files for completed CMRAs, and updated its FWRA.
Kirkwoods, in the London borough of Harrow, where conveyancing forms around three quarters of the work, received a financial penalty of £3,476. Between 6 October 2011 and 25 June 2017, the SRA said the firm failed to establish and maintain appropriate and risk-sensitive policies and procedures (P&Ps).
From 26 June 2017 until 11 February 2025, the firm did not regularly review, update and maintain a record in writing of its PCPs, and between 26 June 2017 and 11 January 2022, Kirkwoods failed to keep a FWRA.
Chetty and Patel Limited in Leicester agreed to pay a financial penalty of £15,817 following a desk-based review. Between14 August 2020 and June 2024, the SRA said the firm failed to establish and maintain PCPs or to have a FWRA.
The SRA said that Chetty and Patel’s conduct showed a “disregard for statutory and regulatory obligations and had the potential to cause harm” considering conveyancing forms a significant portion of their work.
Rowswood Legal Limited, Warrington, Cheshire was fined £8,563 with the risk of harm assessed as high (six). Between 26 June 2017 and 17 March 2025, the firm failed to establish and maintain fully compliant PCPs, to have an FWRA in place or to conduct client and matter risk CMRAs.
With the majority of its work coming from conveyancing, the firm also failed to ensure its relevant employees were made aware of the law relating to money laundering and terrorist financing. The SRA said the failings identified formed “a pattern of misconduct”.
KnightStone Legal Services Limited, in Halesowen, Birmingham, which carries out “a significant amount of in-scope work”, received a £7,776 fine. The SRA found that prior to August 2024, the firm failed to maintain records of its risk assessment. Between 13 March 2018 to 16 August 2024 the firm also failed to have an FWRA in place.
The SRA said that whilst KnightStone stated that its fee earners were “considering risk”, this was not recorded and there is “nothing to demonstrate what was considered for each client and matter”.
HMG Law LLP, in Bicester, Oxfordshire, agreed to pay £25,000 after an SRA investigation found that the firm failed to keep an up to date FWRA between 17 December 2019 and 29 August 2025 despite two thirds of their work coming from conveyancing. The SRA then further uncovered that HMG Law did not regularly reviews and update PCPs between July 2019 and 29 August 2025.
In six files, the firm failed to follow or implement its own PCPs and did not conduct CMRAs.
And finally, Burgh Thorpe Limited, in Peterborough, attracted a penalty of £12,798 for not following the PCPs they had in place since January 2023, shortly after starting to trade. Conveyancing represents a large percentage of the firms’ work. In each of the six files reviewed by the SRA, the firm failed to conduct CMRAs or to follow PCPs.
3 responses
The latest SRA fines for AML non‑compliance should trouble anyone who still believes in proportionate regulation. Because let’s be honest: Conveyancers are now being squeezed from every direction at once:
A proposed government levy on client‑account interest
Endless consultations on everything from homebuying reforms to the most controversial versions of commonhold
An AML regime already buried under a mountain of red tape from OPBAS, the LSB, and the SRA — with whispers of a new “super‑regulator” waiting in the wings, and a law‑tech sector that has spent years running a campaign to dumb down the coalface, and replace professional judgment with dashboards.
Yet despite all this, the profession is still being met with a hostile enforcement posture, as though conveyancers were the weak link in the fight against organised crime. The evidence simply does not support that narrative. Actual money laundering by property lawyers is vanishingly small. But the enforcement culture continues to treat technical breaches, paperwork imperfections, and human error as if they were acts of complicity. It is driving good practitioners out of the field at the very moment the market needs experience. And then we have the regulatory debacle surrounding the collapse of the PM Law Group. If anything demonstrates the fragility of the current regulatory model, it is that.
Which is why there has never been a more urgent moment for the Law Society to transition from its current location to a modern, professional, slimmed‑down, and democratically centred guild or institution capable of defending the profession, restoring trust, and re‑establishing regulatory sanity.
The profession deserves better. The public deserves better. And the rule of law certainly deserves better.
well said Stephen, but I fear you are pi55ing against the wind.
Why don’t these companies just use company’s like Lawtech, Verify 365? They are safe harbour compliant and entire onboarding process completed without breaking a sweat.
Guess they are just being penny smart…