In a move that underscores the Solicitors Regulation Authority’s (SRA) escalating campaign against lax anti-money laundering (AML) controls, South-East London-based law firm Amphlett Lissimore Bagshaws—trading as Amphlett Lissimore—has been fined a staggering £114,000 for persistent failures to comply with statutory AML requirements. The fine, issued on July 29, 2025, is among the largest handed down by the SRA and comes amid a wider crackdown on law firms that fail to meet the stringent standards demanded by the 2017 Money Laundering Regulations.
Details of the Breaches
The SRA’s AML proactive supervision team uncovered significant shortfalls at Amphlett Lissimore during a desk-based review, which found that—from December 2019 to March 2024—the firm had failed to establish and maintain fully compliant AML policies, controls, and procedures (PCPs). Most notably, the firm lacked an effective client and matter risk assessment (CMRA) system, placing it in direct breach of regulatory expectations.
Although Amphlett Lissimore had policies on file, they did not amount to the robust, actively enforced controls required by law. Importantly, there was no consistent or documented risk assessment process for clients or matters, a core component in countering money laundering risks entrusted to the legal sector.
SRA’s Calculation and Reasoning for the Fine
Following its fining guidance, the SRA determined that the breach warranted a penalty equal to 2% of the firm’s annual turnover, resulting in the headline figure of £114,006. In issuing its decision, the SRA explained that the violations “persisted for longer than was reasonable” and “had the potential to cause harm to the public interest and to public confidence in the legal profession.” The regulator’s penalty also serves as a stern warning to other firms, highlighting the minimum expectations regarding AML compliance from all regulated entities.
Due to Amphlett Lissimore’s status as an alternative business structure (ABS), the SRA was able to levy a far higher sanction than its £25,000 cap for traditional law firms—the maximum for ABSs being set at an enormous £250m. Beyond the fine, the firm was ordered to pay £1,350 in costs.
Amphlett Lissimore’s Response and Remedial Action
Amphlett Lissimore responded with full cooperation throughout the SRA’s investigation. The firm has since overhauled its AML safeguards, implementing a new, compliant risk assessment process and updating its policies and procedures to meet all current regulatory standards. The SRA acknowledged these remedial efforts and the absence of evidence showing actual harm materialized as mitigating factors in the final decision.
A spokesperson for Amphlett Lissimore said, “We acknowledge the findings and regret that our previous procedures fell short of the standards required. We have made comprehensive improvements to our AML processes and are fully committed to upholding the highest standards of compliance in the future.”
Industry Context and Compliance Pressure
Amphlett Lissimore is a member of both the Law Society’s Conveyancing Quality Scheme (CQS) and Lexcel scheme—industry marks that are predicated on adhering to high compliance standards, including AML obligations. Recent reporting has surfaced concerns about the rigor with which member firms are actually policed under these schemes, given the number of AML infractions emerging from among their ranks.
The past two years have seen a notable surge in SRA enforcement activity, with a succession of fines targeting firms for comparable failings: deficiencies in PCPs, absence of comprehensive CMRAs, and not maintaining a firm-wide risk assessment (FWRA). Recent fines include £10,719 for Birmingham-based JR Jones, £6,362 for Poole’s O’Haras, and £2,137 for Richard Kanani & Co—all firms registered under CQS.
According to the SRA’s AML annual report, almost 1 in 5 files reviewed in the last year lacked a proper client and matter risk assessment, and 12% contained risk assessments deemed ineffective due to unclear rationales for risk ratings. These numbers, though improved from previous years, still suggest widespread difficulty among firms in meeting AML expectations.
Legal Sector Reaction
Compliance professionals and sector observers view the scale of the Amphlett Lissimore fine as indicative of an environment where scrutiny is only set to intensify. Law Society guidance and various compliance consultancy bodies continue to warn firms not to underestimate the practical and reputational risks of AML breaches.
An SRA spokesperson reiterated, “Our enforcement action illustrates that anti-money laundering obligations must not be treated as a box-ticking exercise. Persistent failures not only expose the legal sector to criminal abuse but also fundamentally undermine public trust. We expect all firms to meet, and continually maintain, the standards set out in the regulations.”
Broader Regulatory Changes and Evolution
Coinciding with the fine, a regulatory threshold change comes into effect on July 31, raising the bar for submitting a defence against money laundering (DAML) suspicious activity report (SAR) from £1,000 to £3,000. This adjustment means lawyers will not commit a money laundering offence if the value of suspicious property in a transaction is below £3,000, simplifying compliance in routine transactions, especially conveyancing, but underlining the importance of robust AML systems in higher-value transactions.
The Amphlett Lissimore sanction is a watershed moment for law firm compliance in the UK, signaling a new era of robust enforcement where regulators expect not just written policies but living, functioning systems that genuinely mitigate money laundering risks. With fines climbing and scrutiny tightening, law firms—large and small—can expect closer supervision, particularly those operating in higher-risk practice areas such as conveyancing.
For clients, these developments may bring increased transparency and reassurance. For firms, however, they are a sober reminder that proactive AML compliance is now a non-negotiable core business activity, not merely an administrative burden.
The £114,000 penalty against Amphlett Lissimore stands as a stark warning: the SRA will no longer tolerate complacency over AML duties. Firms must take the opportunity to reassess their internal controls, training, and ongoing risk assessment protocols, to ensure they remain both compliant and trusted stewards of the UK’s legal system