Decisions shared by the Solicitors Regulation Authority in July reveal 13 firms have been fined a total of £275,170 for AML breaches dating back to 2011 – with one firm fined £114,006.
Amphlett Lissimore Bagshaws in London received the hefty sanction for failing to implement adequate policies, controls and procedures (PCPs) and failing to conduct client and matter risk assessments (CMRA) between December 2019 and March 2024.
Many of the penalties announced in July relate to historic breaches, with one going as far back as 2011. The slew of decisions appear to reinforce the SRA’s recent warning that AML enforcement is set to increase.
Along with Amphlett Lissimore Bagshaws, firms receiving AML penalties announced in July include:
- Andrew & Andrew Solicitors Limited, Portsmouth
Fined £25,000 for failure to have in place an appropriate firm wide risk assessment (FWRA) and failure to conduct CMRAs between June 2017 and January 2024.
- Buglear Bate & Co, Woking
Fined £4,652 for failing to document CMRAs, including failure to determine the extent of customer due diligence (CDD) measures on a risk-sensitive basis between October 2011 and June 2017, and failing to undertake CMRAs on eight files reviewed between June 2017 and March 2025.
- Cooklaw Solicitors Ltd, Sunderland
Fined £25,000 for failure to have appropriate FWRAs and failure to regularly review and update PCPs between November 2020 and November 2024.
- Cotterhill Hitchman LLP, Sutton Coldfield
Fined £12,709 for failing to conduct CMRAs at the appropriate times following review of eight files, six of which had CMRAs ‘dated significantly later’ than the completed transactions.
- Fellowes Solicitors LLP, Walthamstow, London
Fined £15,023 for failure to conduct CMRAs in four files, failure to conduct appropriate CDD in two files, and failing to follow or implement its own policies, controls and procedures (PCPs) in four files.
- Harrowell & Atkins, Berkhamstead
Fined £25,000 for failing to have in place a documented FWRA between June 2017 and 2024, failing to establish and maintain appropriate and risk-sensitive policies and procedures (P&Ps) and PCPs between October 2011 and June 2025, failing to determine the extent of CDD measures on a risk-sensitive basis between 2011 and 2017, failing to carry out CMRAs on five of the files reviewed related to the period from June 2017 to May 2025, and failing to identify and verify (ID&V) source of funds on five files reviewed.
- J R Jones Solicitors, Sparkhill
Fined £10,719 for failing to determine the extent of CDD on a risk-sensitive basis between October 2011 and June 2017, failing to conduct CMRAs beween June 2017 and January 2025, and failing to establish fully compliant PCPs between June 2017 and January 2025.
- O’Haras Solicitors, Poole
Fined £6,362 for failure to have in place an appropriate FWRA between June 2017 and October 2023.
- Richard Kanani & Co Ltd, Farnham
Fined £2,137 when five out of six files reviewed were found to lack any form of documented CMRA.
- Stapletons Solicitors Limited, Palmers Green, London
Fined £9,767 for failing to maintain a written record of PCPs between June 2017 and 2024. Following a review of all files, 49% of conveyancing matters were found to be lacking a CMRA.
- Stephensons, Brierley Hill
Fined £15,051 for failing to have in place a documented FWRA between June 2018 and November 2024 and failing to carry out CMRAs based on five of six files reviewed.
- Worsdell & Vintner, Uxbridge
Fined £9,744 for failure to have in place a documented FWRA between June 2017 and October 2024, failing to establish and maintain PCPs between June 2017 and October 2024, and failing to conduct CMRAs between June 2017 and October 2024.
The details of the AML-related sanctions follow the news earlier this month that one firm received a penalty of £172,934 for failing to identify a client as a non-domestic politically exposed person (PEP).
A sole practitioner has also been struck off and ordered to pay tribunal costs of £29,775.84 for multiple breaches of Money Laundering Regulations that described as ‘widespread and fundamental non-compliance with critical regulations’.
4 responses
The big question for me is, where was the COLP, MLRO, MLCO and SRO (CQS/Lexcel firms) during the period of non-compliance, and why didn’t the firms’ AML independent audit functions pick up the issues found by the SRA?
If all of the above roles were held by one person, then it is clear that this is a single point of failure for firms that are not sole practitioners, and should be addressed.
If they didn’t have an FWRA, I can’t imagine they bothered with a Independent AML Audit either!
Having passed a desktop audit with some minor tweaks suggested to wording of procedures I can’t help but wonder how it is that firms had no idea they were required to undertake a firm wide risk assessment or indeed to ensure that risk assessments and CDD is undertaken on all relevant files.
If you are a Compliance Officer then go to the Compliance Officer conference.
Having said that it is a bureaucratic burden imposed on Solicitors and apparently policed with enthusiasm by the SRA which is a direct result of a failure of UK Finance and the Government to protect the UK from money laundering. It is a disproportionate bureaucratic burden with serious consequences with little evidence that breach of the regulations has resulted in money laundering being facilitated.
yep