SRA Enforcement Is at Record Levels - and Getting Stricter
If you work in conveyancing and still treat AML compliance as a box-ticking exercise, the numbers should give you pause. The SRA's Anti-Money Laundering Annual Report for 2024/25 paints a stark picture: combined AML penalties topped £1.5 million - the highest figure on record.
Of 823 firms given a compliance rating during the period, only 13% were fully compliant. A further 54% were partially compliant, and 32% were rated non-compliant. That is a marked deterioration from 2023/24, when 22% of firms met the standard.
The SRA received 426 reports of potential breaches in 2024/25 - an 88% increase over the previous year - and conducted 935 supervisory engagements, up 72% from 545.
Real Fines, Real Firms
In March 2025, Simpson Thacher & Bartlett was fined £300,000 for having no firm-wide risk assessment from 2017 to 2020.
Tolhurst Fisher LLP received a £120,000 penalty for 15 years of non-compliance. Amphlett Lissimore Bagshaws LLP was fined £114,006 for lacking compliant AML controls between 2019 and 2024.
Batchelor Sharp was fined £23,036 after five files had no risk assessments. Stephens Wilmot Ltd was fined £19,383 after failing to verify client ID - leading to £110,910 sent to a fraudster.
The SRA v Dentons case also signals intent. The High Court overturned the SDT's rejection of the SRA's PEP due diligence allegations in March 2025.
Unlimited Fining Powers Are Now in Effect
Under Section 207 of the Economic Crime and Corporate Transparency Act 2023, the SRA now has unlimited fining powers for economic crime breaches. The previous cap was £25,000. Proposed penalty bands include 6-25% of annual turnover, with an uncapped band for the worst offences.
In October 2025, the government announced the FCA will replace the SRA as the single AML supervisor for solicitors by mid-2027.
Where Firms Are Falling Down
Client and matter risk assessments are the single largest cause of referrals - 16% of reviewed files had none, and 39% did not effectively evaluate money laundering risk.
Conveyancing accounts for 73% of all Suspicious Activity Reports filed by law firms.
Lite Checks vs Safe Harbour - Why It Matters
Not all digital identity checks are equal. The distinction between a 'lite' check and safe harbour status is significant.
What is a lite check?
A lite check matches a client's name, date of birth, and address against databases like the electoral roll. The client uploads a passport photo checked via OCR. PEP and sanctions screening are included. This meets the baseline under the Money Laundering Regulations 2017 but does not read the NFC chip, verify the document cryptographically, or provide safe harbour protection.
What is a safe harbour check?
HM Land Registry's Practice Guide 81 defines an enhanced standard built on GPG45:
NFC chip reading - Must read the biometric passport chip using cryptographic keys and verify the digital signature.
Biometric verification - Liveness check against the chip photo, meeting NIST benchmarks (max 0.01% false match rate).
Linking person to property - Two pieces of evidence connecting the individual to the property.
Transferor checks - Additional verification for parties disposing of property.
Why safe harbour protection is critical
If a conveyancer follows the safe harbour standard and the client turns out to be a fraudster, HM Land Registry will not pursue a recourse claim against the conveyancer.
Between 2020 and 2025, HMLR prevented fraud against properties worth over £194 million. In 2024/25, 143 conveyancing fraud cases totalled £11.7 million in losses.
The Case for Proper Digital Verification
Digital onboarding reduces the process from days to hours. One firm reported AML verification took one-tenth of the time after switching from manual checks.
The UK digital identity sector generated £2.1 billion in revenue during 2023/24, growing at 11.7% per year since 2020.
What Conveyancers Should Do Now
Audit your ID verification process - Does your provider meet safe harbour under Practice Guide 81, or only offer lite checks?
Review your risk assessments - Ensure every file has one that genuinely evaluates risk.
Check systems block progression without checks - Matters should not advance with incomplete AML checks.
Prepare for the FCA transition - FCA supervision will likely bring higher expectations.
The fines are larger, enforcement more frequent, and the regulatory bar is rising. Getting identity verification right - and achieving safe harbour status - is one of the most practical steps a firm can take to protect itself.
How Casera Can Help
Casera allows conveyancing firms to order AML and identity verification checks directly through the platform, helping you stay compliant without adding admin overhead. Get in touch to find out more.
