SRA fine follows prolonged failure to maintain AML risk assessment and controls
A Lincoln-based law firm has agreed to pay a £6,203 fine after the regulator found prolonged failures in its anti-money laundering compliance framework.
The Solicitors Regulation Authority (SRA) reached a regulatory settlement agreement with Anthony Clark & Co Limited, a recognised body based at 16a Guildhall Street, Lincoln.
The outcome, dated 19 February 2026 and published on 23 February 2026, was reached by agreement. In addition to the fine, the firm agreed to the publication of the decision and to pay investigation costs of £600.
The SRA investigation followed a desk-based review by its AML Proactive Supervision Team. The regulator identified concerns regarding the firm’s compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017), as well as obligations under both the pre-2019 SRA Handbook and the current SRA Standards and Regulations.
According to the published agreement, between 26 June 2017 and 11 June 2025, the firm failed to maintain a documented firm-wide risk assessment (FWRA) addressing the risks of money laundering and terrorist financing to which its business was exposed. This breached Regulations 18(1) and 18(4) of the MLRs 2017.
Over the same period, the firm also failed to regularly review and update its policies, controls, and procedures (PCPs), contrary to Regulation 19(1)(b) of the MLRs 2017.
The firm admitted that, prior to 25 November 2019, its conduct breached Outcomes 7.2 and 7.5 of the SRA Code of Conduct 2011 and Principles 6 and 8 of the SRA Principles 2011. From 25 November 2019 onwards, it admitted breaches of paragraph 2.1(a) and paragraph 3.1 of the SRA Code of Conduct for Firms 2019, as well as Principle 2 of the SRA Principles 2019.
In assessing sanctions, the SRA categorised the nature of the misconduct as “more serious” with a score of three, noting that the requirement to maintain compliant AML systems had been in force since June 2017. The regulator also referenced its warning notice, first published in May 2019 and updated in November 2019.
The harm or risk of harm was assessed as low. While conveyancing, which formed a significant part of the firm’s work, is considered high risk for money laundering, the SRA found no evidence of harm to clients and noted that the firm demonstrated a robust risk-based approach at the file level.
A basic penalty of £6,892 was calculated in line with the SRA’s financial penalty guidance, before being reduced to £6,203 to reflect mitigation, including cooperation and remedial action.
The agreement confirms the firm must not deny the admissions made or act inconsistently with them.