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Law firm fined after seven years without mandatory anti-money laundering safeguard

SRA fines law firm after finding it operated for years without a required anti-money-laundering risk assessment

Newnham & Jordan Solicitors Ltd has accepted a financial penalty from the Solicitors Regulation Authority after an investigation found the firm had operated for more than seven years without a documented assessment of its exposure to money laundering and terrorist financing risks. The SRA published the regulatory settlement agreement on 20 November 2025, confirming that the Wimborne-based practice will pay a fine of £8,477 together with £600 towards investigation costs.

The SRA began its investigation following a desk-based review by its AML Proactive Supervision Team. According to the regulator, the review identified that from 26 June 2017 until 8 August 2024 the firm did not have a firm-wide risk assessment in place. The assessment is a mandatory requirement under Regulations 18(1) and 18(4) of the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017. It is the document that sets out the particular money laundering and terrorist financing risks a legal practice faces and the measures required to manage them.

The firm admitted that the assessment was not documented during the relevant period. This resulted in breaches of the SRA Principles and Code of Conduct that were in force before and after the introduction of the Standards and Regulations in November 2019. For conduct before that date, the SRA said the failure amounted to breaches of Outcome 7.5 of the 2011 Code of Conduct and Principles 6 and 8 of the 2011 Principles. For conduct after 25 November 2019, the SRA found breaches of Principle 2 and paragraphs 2.1(a) and 3.1 of the Code of Conduct for Firms 2019.

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The SRA said the firm’s failure to maintain a compliant AML control environment created potential exposure to money laundering risks. Although there was no evidence of client harm, the regulator found that the absence of a firm-wide risk assessment left the practice vulnerable because a third of its services fell within the scope of the 2017 Regulations.

In reaching the agreed outcome, the SRA said it took into account several mitigating factors. These included steps taken by the firm to amend its risk assessment, cooperation with both the AML Proactive Supervision team and the AML Investigation team, and early admissions regarding the breaches. The firm is now considered compliant with the 2017 Regulations.

The financial penalty was calculated in accordance with the SRA’s published guidance on setting fines. The regulator placed the matter within Band B, noting that the misconduct represented a pattern of non-compliance that continued for several years after the Regulations came into force. While the initial calculation produced a penalty of £9,419, the SRA reduced it to £8,477 to reflect mitigation.

The SRA said a fine was necessary to uphold public confidence in the profession and to act as a credible deterrent to other firms. It emphasised that compliance with AML legislation is a basic expectation for regulated practices, particularly those involved in conveyancing and other high-risk transactional work.

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