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.
News and Guidance
SRA faces enforcement action over Axiom Ince collapse – The Legal Services Board (LSB) has issued “binding directions” against the SRA following an independent review into the SRA’s handling of the Axiom Ince case. The review found that the SRA did not act adequately, effectively, or efficiently in the lead-up to the firm’s collapse, which resulted in the loss of approximately £60 million in client funds.
The LSB’s enforcement action will require the SRA to improve risk detection, strengthen client money safeguards, and tighten controls where key roles are concentrated in one individual. Read the full LSB statement →
Solicitor apprenticeships safeguarded – The government has confirmed that apprenticeship funding for under-21s will be ring-fenced, following concern that training budgets might be redirected. This secures the future of the solicitor apprenticeship route, offering a vital, debt-free entry into the profession. Read more →
Birmingham-based solicitor charged in POCA case
A controversial solicitor (‘TikTok lawyer’) and an accountant have been charged in a money laundering investigation by the National Crime Agency. The solicitor has downplayed the accusations on social media, telling his followers that “today’s newspapers are only going to be used to wrap up tomorrow’s bag of chips“. Read more →AI-generated citations in strike-off appeal?
In Bandla v SRA [2025] EWHC 1167 (Admin), the High Court struck out an appeal against an SDT decision, after the former solicitor’s grounds of appeal included fictitious case law – possibly generated by an AI tool. The judgment is a warning shot to lawyers and litigants in person relying on unverified sources. Read judgment →Client refuses to accept complaint outcome – what now?
The Law Society has published practical guidance for when a client refuses to accept your final complaint response. It clarifies your obligations and how to direct the client to the Legal Ombudsman. There comes a point when you just have to stop interacting with the complainant. Read more →Legal Ombudsman: guidance on third-party delays
A new spotlight report explores delays caused by third parties, and how firms can manage client expectations to avoid service complaints. The LeO says it won’t hold solicitors responsible for delays caused by third parties, but it does expect them to manage such delays proactively. That means keeping clients informed, chasing updates where appropriate, and taking reasonable steps to reduce the impact on the client – failure to do so could result in an LeO finding of poor service. Read more →Law Society guide: Economic crime levy
The Law Society has published a plain-language guide to the Economic Crime Levy — including when it applies, how it is calculated, and what law firms should expect. Firms regulated under AML rules with annual UK revenue exceeding £10.2 million are required to pay a fixed annual fee, with amounts ranging from £10,000 to £500,000. This levy, collected by HMRC, funds government initiatives to combat economic crime, including investments in technology and resources for agencies like the NCA. Read more →Law Society tool: Compliance calendar for small firms
A useful resource for all practices: this Law Society compliance calendar highlights the key compliance topics to be reviewed during the year, helping firms stay organised. Breaking compliance reviews into manageable monthly chunks is a proven way to avoid “too-big-to-begin syndrome”. Access calendar →
Compliance corner: Over-billing – reportable or not?
Q: Does an isolated incident of over-billing a client need to be reported to the SRA?
A: In this scenario, a recently-qualified solicitor was found to have inflated their time entries on two client matters — adding around 60 minutes per day over the course of a week.
When challenged, they admitted they were worried about meeting billing targets and didn’t realise the seriousness of what they were doing. No client was charged, as the supervisor caught the entries during pre-bill review. The solicitor was remorseful, the firm dealt with the matter internally, issuing a written warning and a mandatory training plan.
But should the SRA be alerted, too?
A: Yes, dishonesty is serious, even at low levels
We wrote about the scourge of “time padding” last year. It is more of a problem in the profession than anybody would like to admit. Where the firm has strong evidence that a solicitor has been falsely filling in time sheets, the reporting duty kicks in.
That’s because under the Code of Conduct a firm has a duty to report serious breaches or anything that the SRA is likely to want to investigate.
Since we know that the SRA has successfully prosecuted people for similar behaviour, resulting in strike off on the grounds of dishonesty, time padding must fall into the reportable bucket.
It’s likely to be a tough call to make, especially if this was a on-off lapse and there was no harm done. But this is why it’s so imperative to ensure your junior staff have a solid understanding of the types of behaviour the SRA takes so seriously.
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
Next free webinar: Getting AI right – a practical guide
We keep hearing that AI is reshaping the legal landscape – from how we draft documents to how we respond to complaints and supervise staff. But what do you need to think about when bringing AI into your firm? And how can you ensure that you’re setting yourself up for success?
Join us for an essential webinar addressing how to get AI right – ethically and practically.
Date: Wednesday 4th June 2025
Time: 12pm
Location: Online (Zoom)
Topics we’ll cover:
- Regulatory responsibilities: Ensuring your AI use aligns with your professional and regulatory duties
- The difference between LawTech and Tech: clarity on what your firm may actually be looking for
- Choosing and implementing AI tools: Procurement, training and support
- Practical use cases: How AI may help with your day-to-day tasks, whether it’s document drafting, complaints handling, legal research or case progression, or business development and automation of key tasks
- What happens when it goes wrong: Real-world examples, and how to protect your practice
- What the future holds: With the first “AI” law firm just authorised by the SRA, where are we going to next ….. and will you be left behind?
This is more than a tech talk – it’s a deep dive into the (imminent) future of legal practice. Equip yourself with the tools and insights to lead responsibly in an AI-driven profession.
Register Now – Places are limited. Priority access to existing clients.
Recording: Wellbeing in the law
“I’ve had people in tears on the phone – not because they’ve done anything wrong, but because they might have.”
That’s what our team hears regularly from risk and compliance professionals in law firms.
In our latest webinar, we brought together wellbeing experts from LawCare, The Solicitors’ Charity, and the Law Society to talk about the invisible pressure on those who keep law firms compliant.
Included in the panel discussion:
COLPs, COFAs and law firm managers are carrying heavy emotional burdens
There are free, confidential support services available (but many don’t know about them)
Law firm leadership must actively support wellbeing – it’s not just an HR issue
Regulators are now linking firm culture to regulatory outcomes
This was one of the most powerful sessions we’ve hosted.
Read our full write-up here.
Recording available here (passcode Ggum$W2Y)
Disciplinary Watch
Adams Burrows – A sole practitioner was fined £4,525 for multiple AML failings, including no policy, no matter risk assessments (CMRAs), and insufficient source of funds checks. Read decision →
Swift Lawyers Limited – The firm was fined £12,759 for AML breaches. Key issues included a missing firm-wide risk assessment and an inadequate AML policy. Read decision →
Sloan Plumb Wood LLP – Another firm penalised for AML issues. They received a £25,000 fine for failing to have a compliant firm-wide risk assessment and AML policy. Read decision →
Pocock’s Solicitors Limited – Fined £11,337 for similar AML shortcomings, notably deficient FWRA and AML documentation. Read decision →
Jamie Hall – A non-solicitor working at a law firm was removed from regulated practice after submitting false overtime claims. The SRA found his actions were dishonest. Read decision →
Ross Clayton – A non-lawyer was also excluded from the profession, this time for failing to properly assess a vulnerable client’s capacity before acting as a certificate provider on a Lasting Power of Attorney. Read decision →
Daniel Smith – A solicitor received a rebuke for acting without clear instructions and allowing the client account to be used despite no underlying transaction. Read decision →
James Thomson – Another rebuke, this time for a solicitor who offered a settlement to a complainant in exchange for not escalating the issue to the SRA or Property Ombudsman. Read decision →
Hudson and Co – The firm was rebuked for failing to return client files and £24,000 held in client account in a timely manner after ceasing to act. Read decision →
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
ICYMI: Back to basics: The quiet power of legal ethics
In this article, the point is made that legal ethics extend beyond mere rule-following; they are foundational to the profession’s integrity and public trust.
Ethical principles, such as acting with integrity and maintaining public confidence, apply to all members of a regulated firm, not just solicitors.
Junior team members are often banned from the profession for unethical conduct. Actions like backdating documents or inappropriate conduct outside of work can have serious professional repercussions.
Have they been told that they are held to the same high standards as solicitors?
ICYMI: Beyond AML: Rediscovering the full picture of legal compliance
Ed Marshall cautions law firms against an overemphasis on AML compliance at the expense of other critical areas.
While AML remains vital, neglecting aspects like client confidentiality, conflict management, supervision, and client care can lead to significant risks.
Ed advocates for a balanced compliance approach that encompasses all facets of regulatory obligations.
ICYMI: Internal audit: Another string to your bow
Sophie Cisler explores the evolving role of internal audit in law firms with Mark Penlington of Irwin Mitchell. Traditionally associated with financial services, internal audit is gaining traction in the legal sector as a means to enhance governance, risk management, and operational resilience.
Implementing an internal audit function can offer law firms a proactive mechanism to identify vulnerabilities, ensure compliance, and foster a culture of continuous improvement.
ICYMI: Prioritising wellbeing strategies
Many law firms now have wellbeing policies—but do they live and breathe them?
In this post, Sam Bray interviews Leigh McKay of Workwise Wellness. It is argued that wellbeing should be a strategic leadership priority, not just an HR initiative. Embedding core values, involving staff in shaping culture, and modelling behaviour from the top down are all part of the shift from box-ticking to genuine cultural change.
Done properly, a strong wellbeing culture can support compliance, reduce risk, and help attract and retain talent.
