Amphlett Lissimore Hit with £114,006 SRA Fine for Prolonged AML Failures

Amphlett Lissimore Bagshaws has come under intense regulatory scrutiny following a £114,006 fine issued by the Solicitors Regulation Authority (SRA), marking one of the largest penalties ever imposed on a UK law firm for anti-money laundering (AML) breaches.

The sanction highlights the increasing regulatory intolerance for AML non-compliance in the legal sector and the serious consequences facing firms that fail to uphold core obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

The firm's compliance failings spanned a four-year period and centred on inadequate policies, controls, and procedures (PCPs), along with a failure to carry out proper client and matter risk assessments (CMRAs). These oversights are fundamental violations of the UK's AML rules. “These core AML obligations are not optional,” the regulator made clear, “but foundational requirements that underpin the UK’s legal sector defence against criminal abuse.” The fine sends a sharp signal that the SRA is prepared to use the full extent of its powers where compliance is found lacking.

UK law firms are legally bound to implement comprehensive anti-money laundering frameworks. The 2017 Money Laundering Regulations require documented internal policies tailored to firm-specific risks, alongside ongoing client and matter risk assessments. As the SRA has regularly stated, compliance must be “embedded, up to date, and demonstrably effective in practice”—a standard Amphlett Lissimore was found not to have met.

SRA fines for traditional law firms are typically capped at £25,000, but as an Alternative Business Structure (ABS), Amphlett Lissimore is subject to higher statutory thresholds.

Under the revised fining powers introduced to deter misconduct in ABS entities, the SRA can levy penalties up to £250 million. In this case, the firm was fined 2% of its annual turnover, signalling the regulator’s intention to ensure fines remain proportionate and effective.

The regulator’s investigation began with a desk-based review carried out by its AML proactive supervision team—a process designed to target high-risk firms for assessment.

Between December 2019 and March 2024, Amphlett Lissimore was found to have failed to maintain a functioning CMRA process and was unable to provide evidence that its AML systems met regulatory expectations. While there was no indication of deliberate misconduct or concealment, the SRA found the failures persisted far too long and presented “a risk to public confidence” and to the sector’s resilience against criminal abuse.

The firm’s cooperation with the investigation, subsequent implementation of proper AML procedures, and remedial actions were acknowledged as mitigating factors. However, the SRA insisted the serious and prolonged nature of the breaches warranted both a financial sanction and public disclosure. “The length of the breach, and the firm’s initial lack of core AML systems, warranted a strong financial penalty and publication of the decision,” the regulator stated.

This case fits into a broader trend of enforcement activity by the SRA, which has increasingly taken action against firms with inadequate AML frameworks. Many of the affected firms, including those recently penalised, are accredited under schemes like the Law Society’s Conveyancing Quality Scheme (CQS) or Lexcel. These schemes are meant to guarantee high professional standards—including AML compliance—raising questions about whether accreditation alone is sufficient. The SRA’s view is firm: paper-based or superficial compliance is no longer acceptable.

According to the regulator, AML policies must be tailored and operational. Firms are now expected to:

·         Maintain an up-to-date firm-wide risk assessment that informs operational controls;

·         Implement effective CMRAs that assess the risk of money laundering in each transaction, not merely tick boxes;

·         Keep full records and audit trails accessible for inspection;

·         Ensure staff are regularly trained on new typologies and emerging risks;

·         Integrate AML processes into onboarding and matter management systems.

The enforcement landscape is also evolving alongside legislative changes. From 31 July 2025, the UK’s threshold for filing a Defence Against Money Laundering (DAML) Suspicious Activity Report (SAR) will rise from £1,000 to £3,000. Under this revision to the Proceeds of Crime Act 2002 (POCA), transactions involving criminal property below £3,000 will no longer require a DAML, reducing the reporting burden while placing a greater onus on firms to detect high-risk activity. Regulators such as the Council for Licensed Conveyancers (CLC) have issued guidance to help firms adapt, particularly in high-volume areas like residential conveyancing.

The SRA has made it clear through its thematic reviews that AML compliance is about much more than policies on paper. It is now focused on the firm’s ability to detect suspicious patterns, respond to evolving financial crime threats, and maintain public trust. Common failures cited include poor documentation of risk assessments, weak record-keeping, and insufficient transaction monitoring.

This latest enforcement action also reignites scrutiny of quality assurance schemes like CQS and Lexcel. These accreditations are designed to promote high standards, with both requiring compliance with AML rules. However, repeated SRA action against scheme members indicates gaps between accreditation and actual performance. Regulators now expect accreditation bodies to:

·         Conduct rigorous annual AML control reviews;

·         Monitor staff training on evolving money laundering tactics;

·         Ensure that risk assessments are not only in place but updated regularly;

·         React quickly to compliance failures with increased oversight.

As the SRA emphasised, AML frameworks must be “dynamic” and capable of adapting to criminal trends and regulatory shifts. This demand for adaptability is echoed in the Financial Action Task Force’s most recent mutual evaluation of the UK, which cited law firm AML compliance as a critical part of the national framework.

In short, the £114,006 fine against Amphlett Lissimore Bagshaws underscores a simple but urgent truth: law firms can no longer treat AML as a compliance afterthought. Without demonstrably embedded systems, thorough oversight, and continual staff engagement, firms risk severe regulatory penalties, reputational harm, and heightened exposure to financial crime. As regulators shift toward a more forensic inspection of compliance quality, firms must prioritise AML as a business-critical function, not a peripheral administrative burden. 

By fLEXI tEAM