It started with a simple question: Should we rethink how we approach the role of the COLP?
But as is often the case, pulling at that thread opened up a wider conversation about governance in law firms — and the risks of placing too much control in too few hands.
For small firms and sole practitioners, it’s common for one person to wear multiple compliance hats — COLP, COFA, MLRO. It can feel like a practical choice. But in the wake of Axiom Ince, it’s time to ask whether this model is still safe or sustainable.
Why it (seems to) make sense
Consolidating compliance roles brings obvious benefits:
- Cost-efficiency – fewer overheads, leaner teams.
- Clarity – everyone knows who’s responsible.
- Agility – decisions can be made quickly without bureaucracy.
In smaller firms, those things matter. But let’s not kid ourselves — there’s a trade-off.
When practicality becomes a risk
Axiom Ince is a case study in what can go wrong when too much responsibility rests with one person. Over £60 million of client money vanished — and the absence of oversight was a key factor.
If one person controls compliance, who’s watching the watcher?
Risks include:
- No internal checks – mistakes or misconduct can go undetected.
- Easier to conceal wrongdoing – fraud thrives in the dark.
- Blind spots – even well-meaning individuals can miss warning signs without second opinions.
Time to talk about role rotation?
Should compliance roles be rotated more often? A growing number of firms think so.
Some of the potential upsides:
- Fresh eyes – different people spot different things.
- Better governance – rotating roles breaks unhealthy patterns.
- Mental health gains – stepping away from relentless responsibility can reduce burnout.
That said, rotation isn’t without its downsides:
- Disruption – changes take time and adjustment.
- Loss of know-how – institutional memory is a real asset.
- Resource strain – not every firm can afford to train up replacements.
It’s not about change for the sake of it — it’s about reducing risk through better systems.
What’s the SRA saying?
The regulator is clearly worried. As of this year, over 2,400 firms have the same person acting as COLP, COFA and MLRO.
Possible reforms being looked at include:
- Splitting roles – banning management from holding all compliance positions.
- Rotation requirements – mandatory term limits for COLP/COFA roles.
Nothing is set in stone yet. But there is clearly appetite to do something.
Axiom Ince was an extreme and, we hope, unrepeatable event. It does however bring into focus the risk of putting all your compliance eggs in one basket.
Because when one person wears too many hats, the whole firm is vulnerable.
Compliance needs a culture shift
A recent Thirdfort report found that only 15% of compliance leads feel their role is taken seriously within their firm. Nearly half said it’s not respected, and over a third expect budgets to fall.
Worryingly, 49% of compliance officers say AML compliance negatively impacts their wellbeing on a weekly basis.
That needs to change.
We need to value the role properly. That means support, investment and shared responsibility. Not leaving it to one person to carry the weight alone.
