9 things we learned about Lawtech and AI from our latest webinar
From hallucinations to hidden usage, our expert panel broke down the real compliance risks of AI – and what firms can do about them. Whether it’s procurement, supervision or client communication, this webinar was packed with practical tips.
The seven stages of AML compliance (when the audit doesn’t go to plan)
Every law firm goes through a process when faced with the fallout of a critical AML audit — from initial disbelief to meaningful change. Sophie Cisler’s latest blog explores this emotional and practical journey, offering reassurance and a path to recovery.
One hat too many? Why it makes sense to rotate Compliance Officers
Are you the COLP, COFA and MLRO? You’re not alone — over 2,400 firms operate that way. But with Axiom Ince still ringing in our ears, is it time to rethink?
In this new blog, Samantha Bray explores:
- Why overloading compliance roles is a governance risk
- What the SRA might change next
- Simple steps you can take to protect your firm now
News and Guidance
Relying on AI hallucinations in court filings = misconduct
In the Ayinde case, the High Court made clear that citing fake cases “qualifies quite clearly as professional misconduct”. Lawyers must not rely blindly on generative AI. The duty of verification remains with the solicitor. This judgment will be of interest to firms experimenting with generative AI tools in client or court work – or those who don’t know who in the firm is using them…
CQS scheme under fire
An investigation by Legal Futures has cast doubt on the rigour of the Law Society’s Conveyancing Quality Scheme (CQS), prompted by the prevalence of CQS-accredited firms being fined by the SRA for AML breaches. With CQS status often relied upon by lenders and clients, this raises serious questions about quality control and oversight.
Compliance officers say “we’re overwhelmed”
Research by Thirdfort has found that 49% of compliance officers say AML compliance negatively impacts their wellbeing on a weekly basis. That’s a sobering statistic, and one that should concern every law firm leader. Compliance roles often comes with high pressure, high responsibility, and limited support.
These findings echo the discussion from our recent Wellbeing in Law webinar. It’s increasingly clear that compliance is not just a regulatory issue, it’s a people issue. Ensuring your compliance colleagues have the resources, authority and support they need is essential for building a healthy, sustainable workplace culture.
Read the webinar write-up
Thirdfort research | The Compliance Paradox
Law Society: no ethical collapse
Despite headline-grabbing misconduct, the Law Society insists there is not widespread “ethical failure” in the profession. In response to an LSB ethics consultation, Richard Atkinson (Law Society president) said:
“The view that professional ethics is not front and centre of how solicitors operate is a misconception which needs to be addressed. Isolated or exceptional events that draw a large amount of public attention are often assumed to be more representative of the way the profession conducts itself than is actually the case.
“The LSB risks drawing disproportionate conclusions that in turn have the potential to lead to overregulation, contrary to the objectives of the Legal Services Act…”
Read the consultation response
“Punitive” AML enforcement criticised
Property lawyers have voiced frustration at what they see as an overzealous AML fining regime, reports Legal Futures. Are we seeing the profession lose confidence in the SRA’s approach? Take a look at the Disciplinary Watch section below for the latest AML fines dished out.
Read the Legal Futures article
Compliance corner: Do I need to repeat sanctions checks during a matter?
Q: We run sanctions checks at the start of every new matter. But do we need to check again later on – for example, just before completion?
A: Possibly – especially in longer-running or higher-risk matters.
Sanctions designations can change at short notice. A client or counterparty who was perfectly legitimate during onboarding may be added to the sanctions list weeks or months later. If you continue acting after that point, you could be breaching sanctions laws — even without knowing.
The guidance on sanctions compliance says firms should consider the duration and nature of the matter when deciding how often to check. There’s no fixed rule, but a risk-based approach is expected.
Practical steps:
- Flag long-running files (e.g. property, litigation, probate) for periodic re-checking.
- Monitor high-risk clients (by sector, geography, or connections) more frequently.
- Re-run checks for higher risk matters before key milestones, such as completion or fund transfers.
- Keep an eye on Office of Financial Sanctions Implementation (OFSI) updates.
Sanctions compliance is strict liability — even an accidental breach can lead to criminal or regulatory consequences. Building in checks at sensible points is a low-effort way to stay safe.
This is not legal advice. If you have a question you would like us to answer in this section, feel free to send it to info@jonathonbray.com
Free CPD
Recording: Getting AI right – a practical guide
Our latest webinar tackled the fast-moving topic of AI in legal practice, with a focus on practical risk management. We explored regulatory duties around transparency, lawfulness and supervision – and asked whether the current framework is fit for purpose in an AI-driven world.
The session covered not just usage risks, but also how firms should procure and deploy AI systems responsibly. The panel shared examples of real-world adoption, stressed the need for governance and competence, and highlighted risks such as hallucinated outputs and client communication failures.
Watch the recording (Passcode: O1t.!FC1) – free for 30 days
Disciplinary Watch
Heather Joan Roberts – A rare example of a dishonesty finding not leading to strike off. Ms Roberts deleted emails relevant to a client complaint, describing it as a “moment of madness”. The SDT accepted the mitigation and ordered suspension from practice for one year.
Hetts Johnson Whiting – Firm rebuked after failing to investigate obvious red flags in a client’s ID documents, and filing them with HM Land Registry.
Salisbury Law – A sole practitioner fined £750 for failing to complete the SRA’s mandatory AML data collection request. A gentle reminder that another round of diversity data collection is under way, with a deadline of 11 July.
Andrew Harris – A non-lawyer manager was removed from the profession after exposing himself during an online training session.
Kashine Taylor – A trainee solicitor was struck off before even qualifying, having worked for nearly a month as a solicitor without a practising certificate.
AML fine summaries
Howard Green LLP – £10,914 fine (~2.5% of turnover) for failing to implement AML policies following inspection. The firm had no evidence of file-level risk assessments or appropriate source of funds checks. Read more
Lynch Hall & Hornby – £16,260 fine (1.6% of turnover) for inadequate source of funds checks on multiple files. The firm had policies in place, but they were not being followed in practice. Read more
Taunton Solicitors – £12,327 fine for failing to complete CMRAs and follow firm policy on AML. In some cases, no ID or source of funds checks were recorded. Read more
Wildings Solicitors LLP – £8,061 fine for missing CMRAs in six conveyancing files. The firm had started remediation before the SRA’s inspection. Read more
Moseley Chapman & Skemp Solicitors Limited – £9,419 fine (1% of turnover) for not having a bespoke firm-wide risk assessment. Read more
Bannister Preston Solicitors LLP – £22,831 fine for conducting CMRAs after the SRA notified the firm of an AML inspection. Retrospective completion was not accepted as mitigation. Read more
Gordons Partnership 2020 Ltd – £77,784 fine (2–3% of turnover) for serious AML breaches including lack of CMRAs, poor client due diligence, policy gaps, and no independent audit. Read more
Perrin Myddelton Limited – £14,995 fine (0.75% of turnover) for using a non-compliant AML policy, and not carrying out proper risk assessments. Read more
Keith R Thompson & Co – £1,536 fine for missing CMRAs on several files. Read more
Training your team: Anti-money laundering
The SRA expects that all ‘relevant employees’ practicing within the scope of the Money Laundering Regulations (MLRs) must receive robust anti-money laundering (AML) training. Now is the time to ensure your firm is compliant. Failure to meet these obligations can result in significant fines and regulatory action.
Our comprehensive AML training is designed to equip your team with the knowledge and practical skills needed to identify, prevent, and report suspicious activities, safeguarding your firm from risk. Ensure your firm stays ahead of regulatory requirements and avoids potential pitfalls by enrolling your team today.
Formats available: Online | In person | On-demand
Don’t miss out—request a free quote today!
Safeguard your practice: Independent AML Audit
What we do – contact us for further information about our services
- Outsourced COLP and COFA support
- Compliance audits
- New firm and ABS applications
- Independent AML audits (Regulation 21)
- Training (online, remote, on demand)
- AML and GDPR workshops
- PII cost reduction
- Remote file reviews
- TPMAs
- Escrow accounts
- AML and sanctions searches
Long read: 9 AML compliance myths and how law firms can fix them
Are you still falling for these AML myths? Think your firm is too small to worry about AML? Relying on ID checks alone? Trusting long-term clients without question? In our latest long read, Jonathon Bray and Jonathan Coleman (FirstAML) expose 9 common compliance myths – and what firms should be doing instead.
Rethinking the COLP: Could regular rotation of the role strengthen compliance, wellbeing, and capability?
Is it time for a COLP rotation? In her latest article, Samantha Bray explores the potential benefits of regularly rotating the COLP role within law firms. While long-term COLPs offer continuity, this practice may lead to fatigue, burnout, and over-reliance on a single individual. The SRA has expressed concerns about the concentration of compliance responsibilities, especially when one person holds multiple key roles.
Implementing a structured rotation of the COLP position could have several related benefits.
Implementing AI in your law firm
Thinking about AI? Sophie Cisler offers a concise, actionable roadmap for law firms ready to move from AI curiosity to confident implementation. She outlines a four-step approach and emphasises that AI is a tool to enhance, not replace, lawyers’ expertise. She advises managing expectations, prioritising client confidentiality, and investing in staff training to ensure effective AI integration.
