What the SRA found in 2024-25, and what it means for your onboarding.

The numbers

In 2024-25 the Solicitors Regulation Authority carried out 935 anti-money-laundering engagements: 317 onsite inspections, 516 desk-based reviews, 71 thematic reviews and 25 independent audits. Of the 833 firms that received a compliance rating, 112 were compliant, 451 partially compliant and 270 non-compliant.

Enforcement followed. The year produced 58 regulatory settlement agreements (£661,200 in fines), 15 adjudicator fines (£292,133) and 14 Solicitors Disciplinary Tribunal cases (£545,650), together over £1.5 million. Reports to the SRA about money laundering concerns rose from 227 to 426. Firms submitted 19 suspicious activity reports covering £148 million of suspected proceeds, up from £75 million the year before, and 73% of those involved a conveyancing instruction.

The failures it names

The three most common findings are not exotic. They are the ordinary steps of onboarding, done late or not recorded.

• No risk assessment on the client or matter162
• No source of funds check101
• Inadequate policies, controls and procedures99

Source: SRA, Anti-Money Laundering Annual Report 2024-25

Behind each of these is the same pattern: the fee earner knew the client, so the file was never built. The regulator does not inspect what the fee earner knew. It inspects the file.

What it means for onboarding

Five changes close most of the gap, and none of them needs new law.

• A risk assessment on every client and every matter, written before the first substantive step, with the reasons for the rating.
• A source of funds check that goes back to how the money was earned, not only which bank account it sits in, and a note of what was seen.
• Identification and verification done against the register, with the date it was read, so the file shows when the fact was true.
• One place for the whole file: the register extracts, the client's documents, the assessment and the approval, in the order they happened.
• A named person who approves before the matter opens, and a record that they did.

How we do it

Diligentia reads the company register, the ownership chain, sanctions and VAT first, records what each source said and when, asks the client only for what the registers cannot provide, and rates the matter with the firm's own rule pack. The firm's identification sheet, indicator list and risk file note come out filled in, every fact with its source, and a lawyer approves before anything is produced. It is in pilot with a law firm.