Regulator finds firm failed to properly assess money laundering risks on client files
The Solicitors Regulation Authority (SRA) has fined Hugh Williams Limited £5,705 after identifying anti-money laundering compliance failures across every client file reviewed during an investigation. The decision, published on 14 May 2026, followed a review carried out by the SRA’s AML Proactive Supervision team. The regulator said the investigation uncovered concerns relating to the firm’s compliance with the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, together with breaches of SRA regulatory requirements.
According to the SRA, six out of six client files examined failed to demonstrate that the firm had sufficiently assessed money laundering risks as required under the regulations. The regulator found the firm could not show that appropriate customer matter risk assessments, commonly known as CMRAs, had been completed or that adequate measures had been taken to satisfy anti-money laundering obligations.
The SRA stated that the failings amounted to breaches of both the former SRA Code of Conduct 2011 and the current SRA Code of Conduct for Firms 2019, depending on when the conduct occurred. The firm admitted the breaches as part of an agreed outcome with the regulator.
In its findings, the SRA said the conduct demonstrated a disregard for statutory and regulatory obligations and created the potential risk of facilitating suspicious transactions linked to money laundering or terrorist financing activity. The regulator emphasised that effective anti-money laundering controls are necessary safeguards within the legal sector and that the public would expect solicitors’ firms to comply fully with those obligations.
Despite the breaches, the SRA noted there was no evidence of direct harm to clients or third parties. It also accepted that the risk of repetition was considered low after the firm introduced a compliant CMRA process following feedback from the AML supervision team.
The regulator further acknowledged that the firm had cooperated with both the AML Proactive Supervision and AML Investigations teams throughout the process. The SRA initially calculated a basic financial penalty of £7,131 based on the firm’s turnover and the seriousness of the conduct. However, the penalty was reduced to £5,705 to reflect mitigation and cooperation.
In addition to the fine, Hugh Williams Limited was ordered to pay investigation costs of £600. The regulator said publication of the agreement was appropriate in the public interest and necessary for transparency within the disciplinary process.