St Albans-based firm fined after SRA probe found serious anti-money laundering failings
The Solicitors Regulation Authority has fined Photiades Solicitors Ltd £25,000 after an investigation uncovered significant failures in the firm’s anti-money laundering controls.
The St Albans-based practice, authorised as a recognised body, agreed to the regulatory settlement published by the SRA on 29 September 2025. In addition to the fine, the firm must pay £600 in investigation costs.
The action followed a desk-based review carried out by the SRA’s Anti-Money Laundering Proactive Supervision team. That review identified shortcomings in key compliance areas, including firm-wide risk assessments, client and matter risk assessments, policies, controls and procedures, and checks on the source of funds. The findings led to a referral to the regulator’s AML Investigations Team.
Between June 2017 and February 2025, the firm failed to maintain a compliant firm-wide risk assessment setting out how it identified and mitigated the risks of money laundering within its practice. Over the same period, investigators found that all six files reviewed by the SRA lacked appropriate client and matter risk assessments, as required by regulations.
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The regulator also determined that from June 2017 until February 2025, the firm did not have fully compliant policies, controls and procedures in place to manage and reduce the risks it faced. Further concerns were raised about source of funds checks: on half of the files reviewed, the firm had not obtained adequate documentation to establish the origin of money being used in transactions.
The SRA concluded that these failures amounted to breaches of both the 2011 SRA Principles, in force until November 2019, and the updated Principles and Code of Conduct introduced thereafter. The breaches included failing to run the business effectively and failing to act in a way that maintained public trust and confidence in the profession.
While the regulator did not find evidence that clients suffered harm or that the firm had facilitated criminal activity, it emphasised that the failings posed a significant risk of exposure to money laundering. Around two-thirds of the firm’s caseload involved conveyancing work, an area classed as high risk because of its vulnerability to exploitation by criminals. The firm also carried out other regulated work, including probate and estate administration, which brought further exposure to potential financial crime.
In its decision notice, the SRA described the failures as serious and said the firm should have been aware of its statutory obligations under the Money Laundering Regulations. It noted that the failures persisted for several years. However, the regulator also accepted mitigating factors, including the firm’s cooperation with investigators, its admissions of breach, and steps already taken to rectify the issues.
Photiades Solicitors has since introduced a compliant firm-wide risk assessment, strengthened its policies, controls and procedures, and implemented training to ensure all staff undertake proper client and matter risk assessments. The firm has also reinforced procedures for checking the source of funds in transactions.
The fine was calculated in line with the SRA’s published guidance on financial penalties. The regulator assessed the misconduct as “more serious” and the potential impact as “medium”, placing the sanction in the third penalty band. Based on turnover, the basic penalty would have been £30,000, but the figure was reduced to £25,000 after applying mitigation and proportionality adjustments.
The SRA stated that issuing a fine was necessary to uphold standards, deter similar conduct in other firms, and maintain public confidence in solicitors’ regulation. Publication of the agreement was deemed appropriate in the interests of transparency.