Cameron Clarke Lawyers fined after AML review found no compliant risk assessment for years
Cameron Clarke Lawyers Limited has been fined £6,730 by the Solicitors Regulation Authority after failing for years to comply with key anti-money laundering requirements.
The firm, based at Genesis House in Westerham, Kent, agreed to a regulatory settlement following an investigation by the SRA’s AML Proactive Supervision team. The investigation was triggered by a desk-based review that raised concerns over the firm’s compliance with the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017.
The SRA found that from June 2017 until July 2019, the firm had no documented firm-wide risk assessment in place. Even after one was introduced, the regulator said the assessment remained non-compliant until March 2025. The regulations require firms to evaluate money laundering and terrorist financing risks across a range of factors and to record their findings in a formal risk assessment.
Without a compliant assessment, the SRA concluded, the firm failed to identify and manage the risks inherent in its business. Such risk assessments are regarded as a cornerstone of firms’ AML compliance obligations.
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The regulator said the failings placed the firm in breach of both the SRA Principles 2011 and the Principles 2019. Under the earlier rules, firms were required to behave in a way that maintained public trust and to operate effectively with sound governance and financial management. Since November 2019, the updated regulatory framework has required firms to maintain proper systems and controls to ensure compliance with both regulatory and statutory obligations.
Cameron Clarke Lawyers admitted the breaches. In mitigation, the firm accepted responsibility, expressed remorse, and has since remedied the deficiencies. The firm introduced a compliant firm-wide risk assessment in March 2025 and cooperated fully with the regulator throughout the investigation.
Although there was no evidence of actual money laundering or other suspicious activity, the SRA stressed that the lack of proper systems exposed the firm to potential risk. It said the failings amounted to a disregard for regulatory obligations and could have facilitated dubious transactions had they occurred.
The regulator noted that the failings persisted despite the firm being subject to the regulations since 2017 and despite an SRA warning notice issued in May 2019 that reminded firms of the requirement to maintain proper AML documentation.
In calculating the fine, the SRA assessed the misconduct as more serious because it continued after the firm should have been aware of its obligations. The impact of the failings was judged to be medium, as the lack of risk assessments left the firm exposed to potential abuse in areas such as conveyancing, which formed a significant part of its business.
The starting point for the penalty was set at £8,412, but this was reduced to £6,730 to reflect the firm’s cooperation and remedial action. The firm was also ordered to pay £600 towards the cost of the investigation.
The SRA said a financial penalty was appropriate to uphold public confidence in legal services. It emphasised that the sanction created a credible deterrent for other firms and highlighted the risks when solicitors fail to comply with anti-money laundering regulations.
Publication of the decision was deemed necessary in the interests of transparency. The SRA confirmed that Cameron Clarke Lawyers did not gain financially from the misconduct. However, the regulator concluded that the lengthy period of non-compliance required a public sanction to reinforce professional standards and protect trust in the sector.