Firm admits to years of AML breaches; tribunal cites “serious” failings that risk public trust.
Cockshott Peck Lewis has been fined £24,892.82 and ordered to pay £5,107.18 in costs after the Solicitors Disciplinary Tribunal found the firm guilty of years-long failures to comply with anti-money laundering (AML) regulations.
The tribunal heard that the law firm operated without a legally compliant Firm-Wide Risk Assessment (FWRA) for almost six years, failed to conduct Client and Matter Risk Assessments (CMRAs) on multiple files, and neglected to provide AML training to staff for a six-year period.
Between 26 June 2017 and 15 February 2023, the firm either had no FWRA in place or relied on a generic template that did not meet regulatory requirements. Even when an assessment was eventually drafted, it lacked tailoring to the firm’s services, client base, transaction types, or jurisdictional risks.
An AML inspection by the Solicitors Regulation Authority (SRA) in November 2021 uncovered a raft of compliance failures. These included:
- Four of six client files reviewed were missing CMRAs
- No AML training for any staff between November 2015 and November 2021
- Deficient policies, controls and procedures to mitigate money laundering risks
The Tribunal stressed that under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, all law firms must maintain current, firm-specific risk assessments and ensure regular AML training for relevant employees.
While the panel accepted no actual money laundering had taken place, it found the prolonged absence of safeguards “increased the risk” the firm could be exploited for illicit purposes. “There is an inherent harm to the reputation of the profession when solicitors breach their regulatory rules,” the judgment read, emphasising that AML compliance “fully engages the public interest.”
In mitigation, Cockshott Peck Lewis argued that the breaches stemmed from a misunderstanding of regulatory requirements rather than deliberate avoidance. The firm also noted that its small team of long-admitted solicitors, operating under conveyancing quality accreditation, routinely carried out client checks despite the absence of formal documentation.
However, the Tribunal concluded that the seriousness, scale and duration of the failings warranted a financial penalty. It approved the agreed outcome reached between the firm and the SRA, ordering a £24,892.82 fine to be paid to the Crown and costs of £5,107.18 to the regulator.
The Tribunal assessed the firm’s culpability as high, noting responsibility for AML compliance “belonged solely to the respondent” and was not outsourced. The harm was categorised as significant, given the total absence of a FWRA for nearly six years, repeated failures to conduct CMRAs, and a prolonged lack of AML training.
The decision follows multiple warnings from the SRA that AML obligations are non-negotiable, regardless of firm size or client profile. Risk assessments must be specific, accurate, and up-to-date — and the regulator can demand them at any time.
Cockshott Peck Lewis, recognised since 2012 and offering services in conveyancing, tax advice, trusts, probate, and estate agency, now faces closer scrutiny as it works to restore regulatory compliance.