CF Law fined for failing to maintain compliant anti-money laundering systems for over a decade
The Solicitors Regulation Authority (SRA) has fined CF Law Limited £16,880 after finding the Northwich-based firm failed for more than a decade to maintain adequate anti-money laundering (AML) systems and controls.
The decision, finalised on 22 September 2025 and published on 3 October 2025, follows an SRA investigation prompted by a desk-based review from its AML Proactive Supervision Team.
Investigators found that between 2014 and 2025, CF Law failed to establish and maintain compliant policies, controls and procedures (PCPs) to manage money laundering and terrorist financing risks, breaching both the Money Laundering Regulations 2007 and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
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The firm, located at 20 Winnington Street, Northwich, admitted multiple breaches of the SRA Principles and Codes of Conduct covering both the 2011 and 2019 regulatory frameworks.
Between 1 July 2014 and 25 June 2017, the firm failed to create risk-sensitive AML procedures as required by the 2007 Regulations. This continued under the 2017 Regulations, with the firm failing to establish effective controls between 26 June 2017 and 21 May 2019, and to maintain fully compliant systems up to April 2025.
The SRA also found that the firm failed to conduct client and matter risk assessments on six reviewed files, contravening Regulations 28(12) and 28(13) of the 2017 Regulations.
The regulator said the prolonged failure demonstrated a “pattern of misconduct”, adding that CF Law continued operating with deficient systems even after being aware of its obligations. The lack of compliant controls left the firm “susceptible to money laundering or terrorist financing,” particularly as a significant portion of its work involved conveyancing — a sector identified as high-risk in the SRA’s sectoral risk assessments.
Despite these failings, the SRA acknowledged several mitigating factors. The firm had cooperated fully with the investigation, admitted the breaches early, and has since implemented compliant AML frameworks. It also undertook a comprehensive review of its internal controls to ensure future adherence.
In assessing the penalty, the SRA categorised the misconduct as “more serious” with a medium impact, resulting in a total score of seven under its penalty guidance and placing the fine within Band C.
A basic penalty of £18,756 was calculated based on the firm’s annual turnover, which was then reduced to £16,880 in light of its cooperation and remedial actions. The firm was also ordered to pay £600 in investigation costs.
The SRA said:
“The conduct showed a disregard towards statutory and regulatory obligations and had the potential to cause harm by failing to have a compliant AML control environment in place. It was incumbent on the firm to meet the requirements set out in the Money Laundering Regulations 2007 and 2017. The public would expect a firm of solicitors to comply with its legal and regulatory obligations.”
The regulator confirmed that publication of the agreement was in the public interest, citing transparency and deterrence for other law firms.
CF Law Limited agreed to the outcome and accepted the fine, undertaking not to deny the admitted breaches or act inconsistently with the agreement.
The case reinforces the SRA’s continuing crackdown on AML compliance, with regulators stressing that firms must keep policies under regular review and ensure all risk assessments and monitoring processes meet the requirements of current legislation.
The agreement was signed on 22 September 2025 and formally published by the SRA on 3 October 2025.