SRA finds that client damages were paid to third parties without proper informed consent
A Manchester solicitor has been rebuked by the Solicitors Regulation Authority (SRA) after client damages were paid to third parties without ensuring the clients had given properly informed consent. Aneil Naeem, a solicitor, manager, owner, Head of Legal Practice (HOLP), and Head of Finance and Administration (HOFA) at Amicus Solicitors Ltd, agreed to the disciplinary outcome following an SRA investigation.
The regulator’s decision, published on 4 June 2026, relates to conduct that occurred between December 2021 and May 2023. According to the SRA, Naeem authorised and facilitated payments of client damages to third parties despite failing to verify directly that clients had provided properly informed consent for those payments.
Although written authorities were held on file, the regulator found that Naeem relied on introducer-led authorities and communications rather than personally satisfying himself that the instructions genuinely reflected the wishes of the clients involved.
The SRA concluded that the consent recorded on the files did not meet the regulatory standard required to constitute properly informed consent. Naeem admitted that, as a result, he failed to act in the best interests of each client, contrary to Principle 7 of the SRA Principles.
He also admitted breaching paragraph 3.1 of the SRA Code of Conduct for Solicitors by relying on written authorities and third-party communications instead of independently verifying instructions with clients. The regulator noted that the conduct affected multiple clients and occurred in circumstances involving referral arrangements and third-party financial interests.
In determining sanctions, the SRA took into account several mitigating factors. Naeem stated that he believed valid authority was in place at the time and did not obtain any personal financial benefit from the arrangements. The regulator also accepted that he had demonstrated insight into the misconduct, acknowledging that the threshold for informed client consent is high and that direct contact with each client should have taken place.
The SRA further noted his full cooperation during the investigation and the remedial steps implemented at the firm, including reviewing referral arrangements and strengthening procedures relating to client consent.
Despite those factors, the regulator concluded that a written rebuke was the appropriate outcome because client money had been paid to third parties without properly informed consent and because Naeem held senior management and compliance responsibilities within the firm. As part of the agreed outcome, Naeem accepted publication of the decision and agreed to pay £300 towards the SRA’s investigation costs.