Kirkwoods fined after SRA investigation uncovers prolonged AML compliance failures
A Stanmore-based law firm has been fined following an investigation by the Solicitors Regulation Authority (SRA) that identified long-running failures to comply with anti-money laundering requirements.
Kirkwoods, a recognised body authorised and regulated by the SRA, entered into a regulatory settlement agreement dated 20 January 2026. The outcome was published on 9 February 2026 and was reached by agreement, concluding the regulator’s investigation.
Under the agreed outcome, the firm will pay a financial penalty of £3,476 and £600 towards the SRA’s investigation costs. The firm also agreed to the publication of the settlement in accordance with the SRA’s Regulatory and Disciplinary Procedure Rules.
The investigation followed an inspection by the SRA’s AML Proactive Supervision Team. That inspection, and the subsequent investigation, identified concerns relating to the firm’s compliance with the Money Laundering Regulations 2007 and 2017, as well as the SRA’s regulatory frameworks in force both before and after November 2019.
The SRA found that between October 2011 and June 2017 the firm failed to establish and maintain appropriate, risk-sensitive anti-money laundering policies and procedures, as required under the 2007 regulations. Further failings were identified between June 2017 and February 2025, during which time the firm did not regularly review, update or maintain adequate records of its policies, controls and procedures to manage money laundering and terrorist financing risks.
In addition, the regulator found that between June 2017 and January 2022 the firm failed to keep an up-to-date written firm-wide risk assessment identifying the money laundering and terrorist financing risks to which its business was exposed.
The firm admitted the breaches, which the SRA accepted. For conduct occurring before 24 November 2019, the admissions included breaches of the SRA Principles 2011 and failures to achieve key outcomes under the SRA Code of Conduct 2011, including obligations to maintain public trust, comply with regulatory requirements and operate effective systems and controls. For conduct continuing from 25 November 2019 onwards, the firm admitted breaches of the SRA Principles 2019 and the SRA Code of Conduct for Firms, including failures in governance, record-keeping and regulatory cooperation.
In deciding that a financial penalty was appropriate, the SRA took account of mitigating factors. These included the firm’s cooperation with the regulator, early admissions, and steps taken to remedy the failings. At the time of the SRA’s desk-based review, the firm’s AML controls and risk assessments were found to be compliant, limiting ongoing risk.
However, the SRA concluded that the conduct showed a disregard for statutory and regulatory obligations and had the potential to expose the firm to misuse for money laundering or terrorist financing. Given the firm’s focus on conveyancing work, which the regulator considers high risk, the failures were treated seriously despite the absence of evidence of direct client harm.
Applying its published guidance, the SRA assessed the misconduct as falling within Band B. The final penalty reflected mitigation and the absence of financial gain arising from the breaches.
The SRA said publication of the agreement was in the public interest to promote transparency and maintain confidence in the regulation of legal services.