London firm admits prolonged anti-money laundering failings and agrees to a regulatory settlement
Solicitors Regulation Authority has fined Sylvester Amiel Lewin & Horne LLP £17,302 after an investigation found serious and long-standing failures in its anti-money laundering controls.
The sanction was imposed under a regulatory settlement agreement dated 16 December 2025 and published on 23 December. The firm has also agreed to pay £600 towards the cost of the investigation.
The action followed a review by the SRA’s AML Proactive Supervision team, which identified widespread non-compliance with the Money Laundering Regulations 2017 and successive versions of the SRA’s professional rules.
According to the regulator, between 26 June 2017 and 22 September 2024, the firm failed to maintain an appropriate firm-wide risk assessment identifying and assessing the risk of money laundering to which it was exposed. In addition, in five of six client files reviewed, the firm did not properly assess matter-level risk as required by the regulations.
Sylvester Amiel Lewin & Horne LLP admitted the breaches and accepted that its conduct undermined public trust and fell short of expected standards of governance, compliance and risk management.
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The SRA said the failures spanned two regulatory regimes. Up to November 2019, the conduct breached principles and outcomes in the SRA Handbook 2011, including obligations to maintain public trust and operate effective systems and controls. From November 2019 onwards, the firm also breached the SRA Principles 2019 and the Code of Conduct for Firms by failing to maintain effective governance and comply with legal and regulatory requirements.
In deciding the appropriate sanction, the regulator assessed the misconduct as more serious due to the number and duration of the AML control failings, which demonstrated a pattern rather than isolated lapses. More than half of the firm’s work fell within the scope of the Money Laundering Regulations, with conveyancing forming a significant part of its practice. The SRA noted that conveyancing is a high risk area because of the potential for large sums of money to be laundered through property transactions.
Although there was no evidence of direct harm to clients or third parties, the SRA said the prolonged absence of proper AML documentation increased the risk of the firm being used to facilitate money laundering or terrorist financing.
The basic penalty was calculated at £27,750 based on the firm’s turnover, but this was reduced to £17,302 to reflect mitigation. The regulator acknowledged that the firm had implemented a compliant firm-wide risk assessment before the desk-based review, rectified its failures, cooperated fully with the investigation and posed a low risk of repetition.
The SRA said publication of the agreement was in the public interest to promote transparency and act as a deterrent to other firms. The firm has agreed not to deny the admissions made or act inconsistently with the settlement, failing which further disciplinary action may follow.