SRA fines Johnson Crilly Solicitors £7,294 after AML inspection revealed years of failings
Johnson Crilly Solicitors LLP has been fined £7,294 by the Solicitors Regulation Authority after an anti-money laundering inspection revealed years of non-compliance with regulatory requirements.
The Upminster-based firm, located at 25 Grosvenor Gardens, agreed to a regulatory settlement with the SRA following findings that it failed to meet key obligations under the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017. The failings persisted between June 2017 and early 2025, despite the rules having been in force throughout that period.
The regulator’s investigation followed an inspection by its AML Proactive Supervision team. The inspection found that for more than seven years, the firm did not have in place a documented firm-wide risk assessment to evaluate the money laundering and terrorist financing threats it faced. A compliant assessment was only introduced in December 2024.
The investigation also identified that the firm lacked proper policies, controls, and procedures to mitigate risks of money laundering until January 2025. The SRA stated that such policies are essential to managing financial crime risks and ensuring firms avoid inadvertently facilitating illicit transactions.
Further breaches included failing to maintain adequate records of training for relevant employees. Between June 2017 and October 2024, the firm was unable to demonstrate that staff had been properly equipped with awareness and skills to recognise and prevent money laundering. Training records have since been updated to bring the firm into compliance.
In addition, the regulator found the firm did not carry out sufficient client and matter risk assessments during the same period. Risk assessments are mandatory under the regulations, requiring firms to evaluate and record the level of risk associated with each client and transaction. Only from January 2025 did Johnson Crilly Solicitors introduce a compliant assessment process.
Embed from Getty Images
The SRA said the breaches amounted to a disregard of statutory and regulatory duties and created the risk that the firm could have facilitated money laundering or terrorist financing. While there was no evidence of actual harm, the regulator noted that the firm left itself exposed to serious vulnerabilities over an extended period.
Johnson Crilly Solicitors admitted the failings. The SRA accepted mitigation that the firm has since rectified its processes, introduced compliant documentation, and cooperated with the investigation.
In calculating the fine, the regulator assessed the misconduct as more serious due to its duration and the fact that the firm continued without adequate systems despite knowing the requirements since 2017. The impact was rated as medium because the deficiencies exposed the firm to significant risk. The misconduct was classed as a pattern of failings rather than isolated breaches.
Based on turnover, the starting penalty was £8,581, but the figure was reduced to £7,294 to reflect the remedial action and cooperation shown. The firm was also ordered to pay £600 towards the costs of the investigation.
The SRA concluded that a financial penalty was proportionate and in the public interest. It said that sanctioning the firm served as a credible deterrent to others and underlined the risks posed when solicitors fail to comply with money laundering legislation.
Publication of the decision was deemed necessary for transparency, with the SRA emphasising the importance of public confidence in the profession’s commitment to preventing financial crime.
The regulator noted that Johnson Crilly Solicitors did not gain financially from the misconduct. However, the failures persisted for years, and public sanction was essential to uphold trust in the delivery of legal services.