A licensed law firm has been fined after failing to meet key anti-money laundering obligations
A licensed law firm has agreed to pay a financial penalty of £33,438 after an investigation by the Solicitors Regulation Authority identified significant failures in its compliance with anti-money laundering rules.
CD and R Galaxy UK Opco Limited, a licensed body authorised and regulated by the SRA, entered into a regulatory settlement agreement dated 19 December 2025. The outcome was published on 29 December 2025 and also requires the firm to pay £600 towards the costs of the investigation.
The SRA investigation followed an inspection carried out by its anti-money laundering proactive supervision team. The regulator identified areas of concern relating to the firm’s compliance with the Money Laundering Terrorist Financing Information on the Payer Regulations 2017, as well as the SRA Principles 2019 and the SRA Code of Conduct for Firms 2019.
One of the central failings related to the absence of a written firm-wide risk assessment. Between 26 April 2022, when the firm began trading, and October 2024, the firm did not have a compliant written assessment in place, despite this being a regulatory requirement since June 2017. When asked to provide the document during the pre-inspection process, the firm confirmed it was still being drafted and could not be produced.
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Although the firm later supplied a firm-wide risk assessment and demonstrated that a compliant version had been in place since October 2024, the SRA concluded that the earlier absence amounted to a breach of the regulations over a prolonged period.
The investigation also identified deficiencies in client and matter risk assessments. A review carried out by the firm found that not all files contained completed risk assessments or the appropriate level of customer due diligence. Some of the affected files originated from the firm’s previous owner.
The firm self-reported these issues to the SRA on 27 May 2025 and instructed an external law firm to remediate the non-compliant files. The firm indicated that this remedial work was expected to be completed by the end of December 2025.
The SRA said the failures showed a disregard for statutory and regulatory obligations and had the potential to cause harm by increasing the risk of money laundering or terrorist financing. While no actual harm was identified, the regulator stressed that the public expects law firms to meet these obligations as a minimum standard.
In determining the penalty, the SRA took into account the seriousness of the misconduct, the low risk of harm, and the firm’s cooperation throughout the investigation. The regulator also noted that the firm did not benefit financially from the breaches and had shown remorse.
The agreed outcome confirms that the fine will be published in accordance with statutory requirements. The firm has also agreed not to act inconsistently with the settlement agreement, with any failure to do so potentially resulting in further disciplinary action.