2025 has brought a sharp escalation in enforcement action against UK law firms over anti-money laundering (AML) failings, with regulators handing out some of the largest fines seen to date.
According to KYC360, the Solicitors Regulation Authority (SRA) and the Solicitors Disciplinary Tribunal (SDT) have signalled a more uncompromising stance, stressing that inadequate compliance processes will no longer be tolerated.
One of the highest penalties this year came in March, when Simpson Thacher & Bartlett’s London office was fined £300,000 following an SRA review. The U.S. firm was found to have longstanding weaknesses in its control framework, including the absence of a compliant firm-wide AML risk assessment and deficiencies in client and matter risk assessments. Although there was no evidence of actual money laundering, the regulator highlighted the heightened exposure to financial crime risk. The firm has since invested in remediation measures.
Taylor Vinters, which has since merged with Mishcon De Reya, was fined £172,934 in July over its handling of a 2017 property transaction. Regulators found that the firm failed to identify a beneficial owner’s Politically Exposed Person (PEP) status before completion and even provided inaccurate assurances to counterpart solicitors. The case demonstrated how lapses in due diligence, even years before discovery, can carry significant financial consequences.
Another notable case involved Tolhurst Fisher LLP, which received a £120,000 fine in May. The SDT determined that the firm had failed to comply with two sets of AML regulations over a 15-year period. Weak customer due diligence (CDD), including poor source-of-funds checks, and a failure to act on repeated regulatory guidance were among the cited failings. Tolhurst Fisher has since taken corrective steps.
Amphlett Lissimore Bagshaws LLP was fined £114,006 in July after an SRA review found the firm lacked compliant AML controls between 2019 and 2024. Although the SRA acknowledged the firm’s cooperation and remediation, it stressed that the absence of a formal risk assessment process and non-compliant policies had created avoidable risks.
In June, Gordons Partnership 2020 LTD was fined £77,784. The SRA reported systemic weaknesses in risk assessments, policies and procedures across the firm. While no laundering activity was identified, regulators emphasised that deficiencies in governance expose firms to unacceptable levels of financial crime risk.
Also in June, T G Baynes Solicitors faced a £63,869 fine after a review uncovered six years of non-compliance, stretching from 2018 to 2024. While the firm achieved compliance during the investigation, the penalty was based on its turnover and the regulator’s assessment that the breaches persisted for “longer than reasonable”.
These cases underline some critical lessons for the wider legal profession. First, firms must ensure they maintain a living AML risk assessment, backed by robust policies, controls, and documented client and matter assessments. Second, cultivating a culture of compliance is essential—retrospective fixes do not undo past breaches, and prolonged failures usually attract higher penalties.
A risk-based approach to due diligence remains fundamental, particularly around the identification of PEPs and sanctions exposure, source of funds verification, and ongoing monitoring of higher-risk clients. Firms also need to demonstrate effectiveness through regular staff training, comprehensive record-keeping, and independent audits to identify potential weaknesses before regulators do.
Ultimately, these record fines highlight the SRA and SDT’s intent to make AML compliance a strategic priority for the legal sector. Penalties can no longer be dismissed as a manageable cost of doing business. Instead, law firms are being urged to view compliance not only as a regulatory obligation but also as a means of building trust, improving client experience, and reducing inefficiencies in the long run.
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