SRA fines bowers for failing to maintain client risk assessments under AML rules
The Solicitors Regulation Authority (SRA) has fined London law firm Bowers £4,808 after finding it failed to properly record client and matter risk assessments as required under anti-money laundering (AML) regulations.
The firm, based at Unit 2, Technology Park, Colindeep Lane, London NW9 6BX (SRA ID 47468), also agreed to pay £600 in investigation costs. The fine was confirmed through a regulatory settlement agreement dated 26 September 2025 and published on 7 October 2025.
The SRA’s investigation followed a desk-based AML review by its Proactive Supervision Team, which identified compliance weaknesses in Bowers’ procedures relating to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017).
According to the SRA, Bowers failed to maintain adequate client and matter risk assessment (CMRA) records on eight client files. This meant the firm could not demonstrate that it had assessed the level of money laundering risk in each case or that it had adequate systems to monitor compliance with its AML policies and controls.
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The regulator said the firm’s failure breached several provisions of both the 2011 and 2019 SRA Principles and Codes of Conduct. These included:
- Outcome 7.5 of the SRA Code of Conduct 2011, requiring compliance with legislation including AML rules;
- Principle 6 of the SRA Principles 2011, requiring solicitors to maintain public trust;
- Principle 8 of the SRA Principles 2011, mandating sound business governance and risk management;
- Principle 2 of the SRA Principles 2019, which requires solicitors to uphold public trust and confidence in the profession; and
- Paragraphs 2.1(a) and 3.1 of the SRA Code of Conduct for Firms 2019, which require firms to have effective systems and controls to ensure compliance.
The SRA found that the breaches occurred after the introduction of the MLRs in 2017 and continued even after the firm knew its processes were non-compliant. Although no evidence of money laundering or client loss was found, the regulator said the lack of proper AML documentation left the firm vulnerable to potential abuse.
The investigation also found that around a quarter of the firm’s work involved conveyancing — an area the SRA considers high risk for money laundering. Without adequate CMRAs, the firm could not show it had taken proportionate measures to manage those risks.
The SRA categorised the nature of the misconduct as “more serious”, assigning it a severity score of three under its published penalty guidance. The risk of harm was rated as low (score of two), giving a total score of five and placing the case within Band B of the regulator’s penalty scale.
This band typically attracts fines of between 0.8% and 1.6% of a firm’s domestic turnover. The SRA calculated a basic penalty of £5,342, later reduced to £4,808 to reflect mitigating factors.
The regulator acknowledged that the firm had since introduced a new CMRA process, documented assessments on all active files, and taken steps to strengthen its AML controls. The firm also cooperated fully with investigators and admitted the breaches at the earliest opportunity.
In determining the fine, the SRA said it considered the conduct to have shown a “disregard for statutory and regulatory obligations,” but accepted that the firm’s remediation efforts and cooperation reduced the overall penalty.
The regulator added that the sanction was necessary to “maintain professional standards and public confidence in the legal profession,” describing the outcome as a “credible deterrent” to other firms that may fail to comply with AML obligations.
The SRA emphasised that publication of the decision was in the public interest, ensuring transparency in regulatory and disciplinary processes.
Bowers remains an authorised and recognised body regulated by the SRA and is now considered compliant with the MLRs 2017 following corrective actions.