In July 2025, the Solicitors Disciplinary Tribunal fined an East London firm £58,000 for AML breaches going back six years. The admitted failures included an absence of client and matter risk assessments between 2017 and 2022 and no independent audit until January 2024.
Almost two-thirds of the firm’s work was conveyancing, so this is an instructive case for where enforcement is heading.
Indeed, recent SRA decisions have repeatedly cited weaknesses in client and matter risk assessment (CMRA) as a recurring weakness.
Firms need to pay closer attention to their own risk strategy, or they may face similar consequences.
Assess early
Both the SRA and the incoming FCA supervisory regime have made it clear that risk-based judgements must be supported by evidence.
Moreover, HM Treasury’s 2025 National Risk Assessment again identified conveyancing as a high-risk area for money laundering, and the draft AML regulations due before Parliament this year are expected to push firms further toward demonstrable, documented decision-making.
In practice, this will mean a CMRA cannot be produced retrospectively. It must be pre-emptive, capturing a client’s risk profile at the point of instruction.
That means identifying and isolating risks before any substantive work begins.
Build defensibly
But too many of those risk assessments are still inconsistent and disconnected. Many of them are typed up on Word documents, based on a trail of emails, or built once on a template and never revisited.
With AML supervision getting tighter, those kinds of processes will no longer pass muster.
Without a consistent template, defined risk factors, or a clear audit trail, firms won’t be able to demonstrate and defend their decision-making process.
Meet the regulator’s expectations
Checkboard builds the CMRA into the onboarding flow.
Identity verification, source of funds analysis, and AML screening all feed into one documented report, producing a single defensible risk profile.
The result is a CMRA that is consistent across the firm, completed right when it’s needed, and ready to defend if challenged by the regulators.
Firms still relying on manual processes will struggle to provide the evidence regulators now expect to see.
Find out how Checkboard can turn your CRMA’s into defensible evidence. Book a demo today. https://checkboard.com/marketing-partnerships/todays-conveyancer-contact-page?utm_source=todays+conveyancer&utm_medium=marketing+partnership&utm_campaign=todays+conveyancer+articles
This article was submitted by Checkboard as part of an advertising agreement with Today’s Conveyancer. The views expressed in this article are those of the advertiser and not those of Today’s Conveyancer.
