SRA fines Ray Borley Dunkley LLP after identifying years of non-compliant AML controls
Ray Borley Dunkley LLP has been fined £5,072 after the Solicitors Regulation Authority (SRA) found the firm failed for several years to maintain fully compliant anti-money laundering policies, controls and procedures. The regulatory settlement agreement, published on 27 November 2025, followed an investigation that examined the firm’s conduct between June 2017 and August 2025.
The investigation began after a desk-based review by the SRA’s Proactive Supervision team. Regulators identified concerns relating to the firm’s compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as well as breaches of both the SRA Principles and the relevant Codes of Conduct in force during the period. The SRA found that for more than eight years, the firm did not maintain fully compliant AML procedures and did not regularly review or update them, as required by Regulation 19 of the MLRs 2017.
The firm admitted the breaches. For conduct before November 2019, it accepted that it failed to comply with the SRA Code of Conduct 2011 and Principles 6 and 8, which required firms to comply with legislation and maintain effective governance. For conduct after November 2019, it admitted breaching Principle 2 of the SRA Principles 2019 and paragraphs 2.1(a) and 3.1 of the SRA Code of Conduct for Firms, which require effective governance systems and compliance with regulatory obligations.
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In determining the sanction, the SRA considered mitigation put forward by the firm. Ray Borley Dunkley LLP has since reviewed and amended its AML control environment and is now compliant with the regulations. The SRA noted that the firm cooperated fully with both the AML Proactive Supervision and AML Investigation teams and admitted the breaches at the earliest stage. Regulators also found no evidence of harm to clients.
The SRA concluded that a financial penalty was appropriate due to the length and seriousness of the non-compliance, which created a risk of the firm being vulnerable to money laundering or terrorist financing. The regulator said the public would reasonably expect solicitors to comply with statutory and regulatory obligations and that a fine served the wider public interest by acting as a deterrent.
According to the SRA’s penalty guidance, the nature of the conduct was categorised as more serious, while the impact of harm or risk of harm was considered low. This placed the case in penalty Band B. After applying reductions to reflect mitigation, the fine was set at £5,072. The firm will also pay £600 in investigation costs.
The SRA confirmed that the agreement will be published in line with its transparency rules. The firm has agreed not to deny the admissions contained within the settlement. Any future actions inconsistent with the agreement may result in further regulatory consequences, including possible referral to the Solicitors Disciplinary Tribunal.