The Solicitors Regulation Authority (SRA) continues its aggressive enforcement against anti-money laundering (AML) non-compliance in 2026, issuing fines totaling over £100,000 in recent months to firms failing basic obligations under the Money Laundering Regulations 2017 (MLR 2017). These penalties target persistent issues like absent firm-wide risk assessments (FWRAs), inadequate policies, controls, and procedures (PCPs), and missing client/matter risk assessments (CMRAs), especially in high-risk conveyancing practices. With supervision ramping up via desk-based reviews and onsite inspections, the SRA signals no let-up for solicitors.
Recent High-Profile Fines
Bristol firm Humphreys & Co faced a £24,922 fine after an AML proactive supervision review uncovered non-compliant PCPs from June 2017 to June 2022, with CMRAs missing in six of eight reviewed files. Despite implementing fixes like compliant PCPs and CMRA processes by June 2022, the SRA cited “persistent disregard” for obligations, noting 20% of the firm’s turnover from conveyancing. The penalty reflects the high harm potential in property transactions vulnerable to laundering.
Leeds-based Castle Sanderson Limited drew a £10,462 penalty for not reviewing PCPs from June 2017 to May 2025 and skipping CMRAs in 34 files, where conveyancing comprises 75% of work. HMG Law LLP in Bicester agreed to £25,000—the maximum for traditional firms—after lacking an up-to-date FWRA from December 2019 to August 2025 and failing PCP implementation in six files. These cases highlight how even partial compliance efforts mitigate but do not erase fines.
Patterns in AML Breaches
Across 2026 enforcement, firms repeatedly failed to maintain written FWRAs, update PCPs regularly, or document CMRAs, breaching SRA Principles and MLR 2017. KnightStone Legal Services Limited in Birmingham paid £7,776 for unrecorded risk considerations from March 2018 to August 2024, despite “considering risk” claims, with significant in-scope work. Rowswood Legal Limited in Warrington incurred £8,563 for absent PCPs, FWRAs, CMRAs, and staff AML training from June 2017 to March 2025, forming a “pattern of misconduct.”
Conveyancing-heavy practices dominate, with 75% or more of turnover at risk in cases like Kirkwoods (£3,476 fine for outdated PCPs pre-2025) and Chetty and Patel Limited (£15,817 for no PCPs/FWRA 2020-2024). The SRA assesses harm as “high” due to laundering risks in property deals, reducing some fines for remediation like staff training on source of funds checks. CQS-accredited firms feature prominently among the 14 of 16 fined in early 2026, undermining quality claims.
SRA Enforcement Trends
The SRA’s 2024-25 AML report revealed 935 supervisory engagements—a 72% increase—with 32% of firms non-compliant and only 47% of FWRAs meeting standards. Fines often cap at £25,000 for traditional firms but exceed for ABSs, like CGM Hampshire’s £31,045 in late 2025 for a seven-year FWRA gap. Proactive tools now include data analytics and AI for anomaly detection by 2026, shared with the NCA and FCA.
Earlier waves saw £550,000 in three months to 46 firms, with reductions to avoid tribunal referrals. Burgh Thorpe Limited’s £12,798 fine underscores quick failures post-2023 startup, ignoring own PCPs in six files. All fines fund HM Treasury, emphasizing deterrence over compensation.
Regulatory Obligations and Guidance
Firms must conduct FWRAs considering SRA’s Sectoral Risk Assessment, maintain risk-sensitive PCPs, perform CMRAs per LSAG Guidance (effective April 2025), and train staff. High-risk third countries (HRTCs) via FATF lists trigger enhanced due diligence, with ongoing monitoring for past designations like Laos PDR. MLROs submit suspicious activity reports (SARs) to the NCA; poor quality draws scrutiny.
SRA guidance stresses written records, regular PCP reviews, and sanctions compliance for all firms. Tax advice and TCSP work now often fall in-scope post-2020 amendments.
Implications for Law Firms
These fines erode trust and signal rising scrutiny, with desk reviews and guidance letters targeting weak controls. Remediation—updated FWRAs, training, file audits—lowers penalties but requires proactive steps. Firms should audit AML frameworks against LSAG templates, prioritize conveyancing risks, and leverage SRA case studies.