SRA fines sole practitioner after prolonged anti-money laundering compliance failures
Nicholas Gee has agreed to pay a financial penalty after the Solicitors Regulation Authority identified anti-money laundering (AML) compliance failures spanning more than eight years.
The regulatory settlement agreement, dated 22 April 2026 and published on 29 April 2026, relates to Mr Gee’s recognised sole practice based in Sutton Coldfield. Under the agreement, the firm will pay a fine of £725 and investigation costs of £600.
The SRA launched its investigation following a review by its AML Proactive Supervision team. The regulator identified concerns regarding the firm’s compliance with the Money Laundering Regulations 2017 and the SRA’s regulatory framework.
According to the SRA, the firm failed between 2017 and 2026 to maintain records of client and matter risk assessments required under Regulation 28 of the Money Laundering Regulations 2017. The regulator said this meant the firm could not demonstrate that the measures taken to assess money laundering risks were appropriate.
The investigation concluded that the firm breached several provisions of both the former SRA Handbook 2011 and the SRA Standards and Regulations introduced in 2019. These included obligations to maintain effective systems and controls, comply with anti-money laundering legislation, and uphold public trust in the profession.
The SRA acknowledged that there was no evidence of actual harm to clients or third parties. It also accepted that the firm had assessed risks on files but failed to formally record those assessments as required.
In mitigation, the regulator noted that the firm had since brought itself into compliance by implementing compliant client and matter risk assessments for all active files within the scope of the regulations. It also recognised the firm’s cooperation with both the AML Proactive Supervision and AML Investigations teams.
The SRA stated that the misconduct nevertheless demonstrated a disregard for statutory and regulatory obligations and created a potential risk that dubious transactions could go undetected. The regulator emphasised that AML controls are a critical safeguard against money laundering and terrorist financing.
In calculating the penalty, the SRA assessed the conduct as more serious due to the length of non-compliance and the fact that the firm was a sole practice, meaning responsibility for compliance rested directly with Mr Gee. The regulator reduced the final penalty from an initial £806 calculation to £725 to reflect mitigating factors and remedial action.