Hello again,
This week’s edition is more treat than trick, we hope. We share our takeaways from the SRA COLP COFA conference, and turn our attention to what we don’t know about the FCA’s takeover of AML supervision.
Plus there’s a guide to improving the quality of your client and matter risk assessments. More of that in our free half-day AML workshop on 19th November.
Our usual Disciplinary watch features short SDT micro-stories you can use in team training, plus a quick round-up of the latest AML fines.
Jon and the team
11 Things we learned at the SRA’s COLP COFA conference 2025
The SRA’s COLP COFA conference was unusually frank this year. From a “more intrusive” supervisory approach to the FCA’s grab for AML supervision, Mazur fallout and the SRA’s view that AI will reshape practice, we’ve distilled 11 takeaways firms need to know about.
Keep calm and CMRA on: Everything we don’t know about FCA supervision of AML
With the FCA set to take over AML supervision, nobody can say exactly how this is going to affect compliance in law firms. Sophie Cisler cuts through the speculation and sets out what firms need to be thinking about while the goalposts are moving.
Turning risk assessments from an admin task into a proper AML control
Too many firms still treat client/matter risk assessments as paperwork, says Ed Marshall. This piece shows how to turn them into a live AML control that drives decisions and actually reduces risk.
News and Guidance
SRA – AML annual report 2024/25 – The SRA’s latest AML report (covering 6 April 2024–5 April 2025) shows a marked step-up in supervision and enforcement. The regulator engaged with 935 firms (317 onsite inspections; 516 desk-based reviews). Of 833 firms given a rating, 32.4% were non-compliant.
5,569 firms are now in scope (about two-thirds of those authorised). On enforcement, the SRA received 426 ML-related reports (up from 227), leading to 151 outcomes (137 internal; 14 SDT). Adjudicator fines totalled £292,133 (15 cases) and RSAs £661,200 (58 agreements). SDT fines hit £545,650 across 13 cases.
Themes are familiar: weak FWRAs, missing/poor PCPs and CMRAs, and insufficient SoF/EDD. Nearly half of firms had an “independent audit”, but almost a third of audits reviewed were non-compliant due to no file reviews (our independent audit service includes file review). The report also nods to the government’s decision for the FCA to become the single AML supervisor for professional services (subject to legislation and transition).
Pre-Mazur: calls to lift threat of historic prosecutions (Law Gazette) – A leading silk has urged the SRA to remove the threat of pre-Mazur prosecutions, arguing fairness and legal certainty. Useful context for firms reviewing historic supervision models and job titles.
Mazur resources (SRA and Law Society) – The SRA’s hub on “conducting litigation” and the Law Society’s practice note both clarify that only authorised persons may conduct litigation; unqualified staff can assist but not conduct, and supervision alone is not a remedy. Worth circulating to litigation teams, but there is still plenty of grey area to navigate.
Upholding professional ethics (SRA hot topic) – The SRA has organised its materials on culture, integrity and everyday decision-making.
Pooled client accounts – Law Society pushback – The Law Society warns that proposed MLR changes could impose heavy CDD burdens on pooled accounts.
First-tier complaints handling – SRA thematic review – The SRA’s review highlights uneven triage, weak root-cause analysis and thin board visibility. Expect further SRA guidance and warnings about complaints handling.
Compliance corner – are solicitor review sites optional?
Q: We are a corporate law firm. Do we have to engage with consumer-focused review sites, and can we ask them to stop contacting us?
A: No – you’re not obliged to “claim” or manage a profile on private review platforms. These sites often compile firm and contact details from public sources (e.g. SRA register) and may retain a basic listing even if you don’t engage. You can, however, tell them you don’t wish to be contacted and ask to be removed from their marketing lists. That is consistent with UK GDPR; individuals (and contacts at firms) have an absolute right to object to direct marketing, which organisations must honour.
If you do choose to engage with review sites, treat them as regulated marketing channels. The SRA expects client information and publicity to be accurate and not misleading, and it has specific guidance encouraging constructive engagement with online reviews – without breaching confidentiality. Responding to reviews is fine provided you don’t disclose confidential or privileged information, and your tone and claims remain compliant.
Practical steps
- If you don’t want to engage: Reply once to withdraw consent/objection to further marketing and ask for removal from mailing lists; keep a copy. You can ignore future sales approaches after that.
- If you do engage: Appoint an owner (e.g. marketing or complaints lead) to monitor platforms, set a “no confidential details” rule, and align responses with the SRA’s publicity and online reviews guidance.
- Either way: Make sure any public statements about services, success rates, or fees are fair, evidence-based and not misleading; keep screenshots/records of any disputed reviews and handle them through your complaints process where appropriate.
You can opt out of the sales push and still leave any basic listing alone. If you opt in, do it deliberately: comply with the publicity rules, protect confidentiality, and manage reviews with a light but consistent touch.
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 session: Half-day AML workshop (places limited)
Date: Wednesday 19 November (09:30–13:30)
Format: Live virtual Zoom session, broken into discrete sessions
Who should attend: MLROs, MLCOs, COLPs/COFAs, managing partners, onboarding leads and anyone responsible for AML systems.
In association with our friends at FirstAML, we are excited to invite you to a half-day masterclass-style session.
Our panel will take a fictional firm through the AML framework to ensure they have all the building blocks in place. From risk assessment to training and audit, attendees will come away with a better understanding of how it all fits together.
AML guidance usually focuses on one specific aspect of compliance, at the expense of the broader context of the framework within which it sits. The aim of this session is take a birds eye view, to make AML compliance less daunting for busy practitioners.
Register Here (places strictly limited)
Recording: Solicitors’ PII market update
PII renewal without the scramble
This session focused on doing the simple things early and well so your professional indemnity renewal isn’t a last-minute firefight. We opened with market context: while renewals now happen year-round, a large tranche of firms still bunch around the autumn peak, putting pressure on brokers, underwriters and finance teams. The practical approach is to start early, leaving around 16 weeks to produce a compelling evidence-led proposal for insurers.
A recurring theme was the one-page renewal narrative: a concise statement of who you are, what’s changed since last year, your key exposures, and the specific controls you’ve strengthened. Underwriters reward clarity and proof over vague assertions and lack of detail.
Common pitfalls came up repeatedly: vague or copy-pasted answers, late or partial submissions, and narratives that haven’t caught up with reality (new services, panel terms, staffing changes). For higher-risk practices (e.g. conveyancing, high volume claims) the message was to show you understand risk and offer evidence of mitigation. Small firms were reminded that lean controls can still be persuasive if they’re specific and evidenced.
Broker engagement was another strand: speak to your broker before you submit to sense-check issues and target markets. After submission, be responsive; and don’t be afraid to get a second opinion.
If you missed it – or want colleagues to catch up – watch the recording here.
Disciplinary Watch
Charles Ogbonna Azotam (strike off) – Sole principal misappropriated client money over four years, creating a £163,112.83 client-account shortage that was never replaced; also issued two large cheques to a client knowing there were insufficient funds, and failed to keep compliant books. Dishonesty admitted so strike off inevitable.
Kathryn Poole (strike off) – Family lawyert told her client and firm that pension information had been requested when it had not, then let a court deadline pass and blamed the provider; also failed to tell the client/firm about a penal notice and costs order. The tribunal found dishonesty and imposed strike off.
Nasar Hussain (suspension) – While pursuing his own PI claim, failed to ensure his prior medical history was fully and accurately disclosed for the expert report and the issues in dispute. Breaches of Principles 1, 2 and 5 were proved; dishonesty was not found. Four-month suspension, suspended for two years.
Daniel Jones (£1,500 fine) – Told a family client that a Decree Nisi application had been lodged when it had not, causing distress and delay. The tribunal found breaches of Principles 2 and 7 but no dishonesty or recklessness; limited culpability and harm led to a lower level penalty.
Paul Andrew Smith (strike off) – In a 2022 clinical-negligence matter, sent correspondence and filed a witness statement that misled about the availability of client medical records, then doubled down with a misleading response to a court order. Admitted dishonesty, so was struck off.
Landreth Adonis Daniel (suspension) – Acted in criminal proceedings for Person B (the defendant in domestic abuse proceedings) while Person A (the complainant) was his past and continuing client. Then advised Person A on a witness summons the day before B’s trial. The tribunal found he should have known there was an obvious conflict (or significant risk).
David James Chalcraft (strike off ) – Let a client’s claim be struck out in 2012 for non-compliance and then, for a decade, misled the client about its status. Also settled another claim without instructions; provided a banking facility; and as COFA failed to obtain accountants’ reports. Dishonesty admitted for the earlier period; therefore struck off.
Anbananden Sooben (suspension) – PII covering letter to insurers omitted an ongoing SRA investigation and wrongly claimed an internal report had been made. SRA investigators found that client care letters/invoices were created/amended to imply costs information had been given when it had not. Accounts Rules and supervision failures included a £9,120 shortage and missing reconciliations.
Latest AML fines
Sherwood Wheatley – £14,751 for historic AML systems failings (no FWRA/PCPs for years; late CMRAs).
A S Solicitors – £2,429 for missing FWRA and PCPs.
Wenborne Weller & Spooner Ltd – £4,879 for late/non-compliant FWRA/PCPs since start-up.
SM Solicitors – £3,264 for FWRA/PCP defects plus file-level lapses (CMRA, CDD, source of funds).
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!
Most firms need an independent AML audit
What we do – contact us for further information about our services
- Outsourced COLP and COFA support
- COLP coaching
- Compliance audits
- New firm and ABS applications
- Independent AML audits (Regulation 21)
- Training (online, remote, on demand)
- AML and GDPR workshops
- PII reviews
- Remote file reviews
- TPMAs
- Escrow accounts
- AML and sanctions searches
Older posts
Compliance, culture and the competitive edge – Let your ethics speak for you
Samantha Bray says firms can turn ethics into a strong competitive advantage, albeit one that is difficult to quantify.
“Don’t treat clients like commodities” – practical safeguards for mass file transfers
The recent SSB report got us thinking about the mass transfer of client files from one firm to another. This can happen for a multitude of reasons, but one thing that must stay front and centre is the client’s best interests.
Here is a workable framework for approaching the regulatory issues involved.
How to close down your law firm with confidence and compliance
Not that we are wishing this on anyone, but here is a handy round-up of regulatory issues that need to be addressed when closing down your practice.
