Three firms have been fined a total of £43,000 by the Solicitors Regulation Authority for failing to conduct adequate anti-money laundering checks in conveyancing transactions.
The largest penalty, £20,048, was handed to East London firm Richard Pearlman LLP, which the SRA found had failed to conduct sufficient, or any, source of funds checks in six out of eight files it reviewed.
The firm had facilitated dubious transactions that could have led to money laundering or terrorist financing, the SRA found, which could have been avoided had the firm conducted adequate source of funds checks.
“We note from the firm’s email dated 4 February 2025, that a lax approach to SoF checks may have been adopted for various reasons, but in one case, it was because the client was known to the compliance officer for legal practice, through a close friendship with the client’s father,” the SRA noted in its decision.
“Such personal connections or long-standing relationships do not absolve the firm of its regulatory obligation to conduct appropriate SoF checks. Firms must not allow familiarity or existing relationships, including friendships with clients or their family members to override the need for robust SoF checks.
“These checks are a critical safeguard against the risk of money laundering, particularly in property transactions, which are known to be exploited by criminals to launder illicit funds.”
The firm has instructed an external consultancy to ensure compliance with regulatory obligations and delivered bespoke training to fee earners since the inspection. “We also note that the firm has produced ‘a more bespoke and compliant FWRA’,” the SRA said.
Twickenham’s Baron Grey Limited, also known as Baron Grey Solicitors, was fined £17,866 for failures relating to customer due diligence and client and matter risk assessments.
Appropriate CDD measures, including the ID and verification of a client and the ultimate beneficial owner of a client company, were missing in two files inspected by the SRA’s AML Proactive Supervision Team.
The firm failed to conduct appropriate CDD measures relating to the scrutiny of transactions in five files, with missing CMRAs in a further seven files.
“The conduct showed a disregard for statutory and regulatory obligations and had the potential to cause harm, by failing to undertake ID&V, ongoing monitoring, source of funds checks and CMRAs in conveyancing transactions, that could have led to money laundering (and/or terrorist financing),” the SRA said.
“This could have been avoided had the firm ensured compliance, by ensuring staff followed and implemented its own PCPs at file level, as well as had PCPs that made provision for risk assessing clients and matters.”
Ray Borley Dinkley LLP, based in Milton Keynes, was fined £5,072 for failing to maintain fully complaint AML policies, controls and procedures between June 2017 and August 2025.
The SRA said it had assessed the nature of the conduct to be more serious, with a score of three, because the firm had shown ‘a ‘persistent disregard’ of its regulatory obligations and only became complaint following the inspection and subsequent guidance offered by the SRA. “The firm did have an AML policy in place from 2014, which outlined some procedures,” the SRA said.
“However it was not sufficiently detailed or adequate to comply with the regulations, which is serious when considering that a substantial portion of the firm’s work is in the field of conveyancing.”
