Why the SRA’s updated guidance on money laundering matters for conveyancers

The Solicitors Regulation Authority (SRA) has issued updated guidance on money laundering: for conveyancers, this is more than just another regulatory update. Property work continues to be singled out as one of the highest risk areas for criminal exploitation, and the guidance makes clear what the regulator expects to see in practice.

Why now?

The timing is linked to the 2025 National Risk Assessment (NRA), which again rated the legal sector’s money laundering risk as high. Conveyancing, alongside trust and company services and misuse of client accounts, remains the most vulnerable area.

Criminals target property transactions because of the large sums involved, the respectability that legal professionals bring to a deal, and the gaps that appear when source of funds checks are inconsistent. The NRA and SRA are aligned in their message: conveyancers need to take a risk based, not a tick box, approach.

What the SRA expects

The updated guidance highlights several expectations for firms handling property matters:

• Matter risk assessments should clearly explain why you rate a client or transaction as high, medium or low risk.
  
• Enhanced due diligence must be applied in higher risk cases, such as overseas purchasers, complex ownership structures, or unusual funding sources.
  
• Source of funds and source of wealth checks need to go beyond bank statements to genuinely understand where money comes from.
  
• Detailed records should evidence decisions and allow you to justify them if challenged.
  
• Training and supervision must equip staff to spot red flags like unusual purchase patterns, cash deposits or deals that do not match a client’s profile.

Beyond compliance

In my work with firms, I see how easy it is to view AML as a form-filling exercise. But relying on the SRA’s annual questionnaire or a single ID check is not enough. Complacency is the greatest risk: a tick box approach leaves conveyancers open not only to regulatory action but also to serious commercial consequences, from banks refusing funds to insurers excluding cover.

AML compliance should be treated as part of good risk management. If criminals exploit your firm, you risk more than SRA scrutiny. You risk your reputation, your insurer’s support, and your clients’ trust.

Practical steps for conveyancers

If you want to benchmark your current processes against the SRA’s expectations, here are three steps I recommend:

1. Audit recent files: Check whether risk assessments and source of funds checks are clear, proportionate, and evidenced. The SRA are focussing on a lack of or poorly completed client and matter risk assessments – frequent fines for failure! Don’t just collect bank statements, read them – do they tell the complete story or raise any red flags? 
2. Update your firm wide risk assessment: Ensure it reflects the findings of the 2025 NRA and the property specific risks your firm faces.
3. Refresh training: Make sure your team understands how to apply AML obligations in practice, not just on paper.

The SRA’s guidance is not new law, but it does signal how the regulator will approach enforcement. For conveyancers, the warning could not be clearer: AML is not background noise. It is a central part of how we protect our firms, our clients, and the integrity of the property market.

Simon Harbord is a senior associate at Teal Compliance