The Solicitors Regulation Authority (SRA) has issued updated guidance on money laundering, with a particular emphasis for conveyancers, reflecting the persistent high-risk status of property transactions within the legal sector. Property work continues to be singled out as an area particularly vulnerable to criminal exploitation, due to the large sums involved and the opportunity for illicit funds to be laundered undetected. According to the updated SRA guidance, conveyancers must adopt a risk-based approach rather than a mere tick-box exercise when conducting checks, reinforcing the message from the 2025 National Risk Assessment (NRA) that the legal sector remains a high-risk environment for money laundering.

The latest guidance outlines clear expectations for firms handling property transactions. Matter risk assessments must provide clear justification for categorising clients or transactions as high, medium or low risk. Enhanced due diligence is required in higher risk scenarios, which include overseas purchasers, complex ownership structures, and unusual funding sources. Firms are urged to go beyond superficial checks such as bank statements to truly understand the origin of funds and wealth involved. Detailed record-keeping of these assessments and decisions is essential to withstand regulatory scrutiny. Additionally, training and supervision must be geared towards enabling staff to identify red flags including atypical purchase patterns or cash deposits inconsistent with client profiles.

The timing of this update correlates with the NRA for 2025, which continues to portray legal services, and conveyancing in particular, as prime targets for money laundering. Government and regulatory bodies are aligned in their call for a robust risk management approach, discouraging complacency and superficial compliance. The SRA highlights that inadequate or poorly completed risk assessments have been a frequent cause of enforcement actions. Conveyancers face not only regulatory penalties but also serious commercial ramifications if criminals exploit their firm, such as rejection of funds by banks or withdrawal of insurance cover. Effectively, anti-money laundering (AML) compliance is positioned as integral to protecting a firm’s reputation, client trust, and the integrity of the property market as a whole.

Beyond the SRA’s direct guidance, the broader regulatory landscape reinforces the need for vigilance. The SRA’s wider risk assessment, tied to the Government’s NRA, identifies emerging threats including the increased use of offshore companies to conceal beneficial ownership and breaches of client account rules that can create money laundering vulnerabilities. The changing working environment, with greater reliance on electronic verification and consultancy models, adds complexity. Without strong central supervision, these trends risk allowing illicit activity to evade detection. The Legal Sector Affinity Group (LSAG), a collaborative body including the SRA and HM Treasury, has updated its official AML guidance effective from April 2025, which further underlines these evolving challenges and expectations for thorough source of funds checks and compliance.

Practical advice from compliance experts stresses three key steps to align with the updated SRA guidance. First, firms should audit recent conveyancing files to ensure risk assessments and source of funds checks are proportionate, clear, and well documented. Simply collecting bank statements is inadequate; a meaningful review to identify potential red flags is essential. Second, firms should update their firm-wide risk assessments to incorporate the latest NRA findings and reflect property-specific threats. Third, continuous and practical training should be provided to staff so that AML obligations are understood and applied consistently, preventing a mere paperwork exercise. The SRA’s guidance, while not new law, signals intensified regulatory scrutiny and enforcement focus going forward.

The upcoming annual anti-money laundering and financial sanctions data collection exercise will also play a crucial role in monitoring how firms manage these risks. The Office of Financial Sanctions Implementation (OFSI) has recently published its first-ever Legal Services Threat Assessment, highlighting sanctions compliance risks in the sector and urging legal firms to incorporate these findings into their risk management frameworks. Meanwhile, continuing consultations under the Consumer Protection Review could see future reforms around the handling and protection of client money, adding layers to existing compliance duties.

In sum, the SRA’s updated guidance and the wider regulatory environment represent a decisive call to conveyancers to treat AML not as a bureaucratic hurdle but as a core element of good governance and client protection. With the legal sector and property transactions remaining prime targets for financial crime, the consequence of lapses extends far beyond regulatory fines, threatening the very reputation and operational viability of firms involved.

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Source: Noah Wire Services