The UK’s anti-money laundering (AML) regime has entered a more aggressive enforcement phase, and for solicitors, this is no longer background compliance work. The combined force of the Money Laundering Regulations 2017 (MLR 2017) and the Proceeds of Crime Act 2002 (POCA), alongside increasingly assertive oversight by the Solicitors Regulation Authority (SRA), is reshaping expectations across the legal sector.
A Clear Shift in Enforcement
Regulators are no longer focused on whether firms have AML policies; they want proof that those systems actually work. This shift is driven in part by scrutiny from the Financial Action Task Force (FATF), as the UK seeks to demonstrate effectiveness ahead of future evaluations.
The courts have reinforced this tougher stance. In R v Anwoir, the Court of Appeal confirmed that proving money laundering does not require identifying a specific underlying offence; circumstantial evidence may be enough. Meanwhile, R v Da Silva established that “suspicion” is a relatively low threshold, increasing the likelihood that solicitors must consider reporting obligations.
What the SRA Now Expects
The SRA is taking a more targeted and data-led approach to enforcement. The case of SRA v Dentons UK and Middle East LLP highlighted the regulator’s willingness to scrutinise AML systems in complex transactions, even where no misconduct is ultimately found.
In practice, firms must go beyond basic client checks. Under the MLR 2017, there is a clear expectation to understand the source of funds and, where appropriate, the source of wealth, supported by ongoing monitoring throughout the client relationship.
High-Risk Work Under the Spotlight
Certain practice areas remain firmly in regulatory focus. Property transactions, corporate structures, and trust work continue to present elevated risk. These areas are often associated with complex funding arrangements, making them attractive for misuse.
Firm-wide risk assessments are also under closer scrutiny. Regulators expect these to be living documents actively used to guide decisions, not static templates completed for compliance purposes.
Culture and Accountability Matter
There is also a noticeable shift toward accountability at senior levels. Compliance is no longer confined to MLROs; leadership teams are expected to take ownership of AML risk and embed it into firm culture.
Training, supervision, and clear internal reporting lines are now essential. Failures are increasingly viewed as systemic rather than individual, with reputational consequences often matching or exceeding financial penalties.
What Firms Should Do Now
For most firms, the response should be proactive and structured:
- Review and update AML policies in line with current guidance
- Strengthen client onboarding and due diligence procedures
- Ensure effective ongoing monitoring of client relationships
- Invest in compliance systems and technology
- Revisit historic files where risk may not have been fully addressed
The Bottom Line
The direction of travel is clear: AML compliance is now a core operational risk for law firms. With the SRA increasing enforcement activity and the courts supporting a broad interpretation of money laundering offences, firms must move beyond tick-box compliance.
Those that act early will not only reduce regulatory exposure but also strengthen trust and resilience in an increasingly scrutinised environment.
