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The December 2025 AML Crackdown: Is Your Firm Next?

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The first half of December 2025 sent a blunt warning to the legal profession: the SRA will not accept poor AML compliance. A number of enforcement actions has resulted in thousands of pounds in fines for technical failings. In short, you don’t have to launder cash to be penalised—poor record-keeping will do the job.

The Case Files: December Enforcement

  • West Yorkshire (Mirfield) | Published: Dec 1, 2025. The firm was fined £6,236 for a seven-year gap in Firm-Wide Risk Assessments. The SRA cited a persistent disregard for statutory obligations, noting the firm failed to maintain compliant AML policies since 2017.
  • Manchester (Swinton) | Published: Dec 10, 2025. The practice was fined £19,013 following an inspection that found systemic failures in internal AML controls. While the firm had AML policies on paper, they were not being applied effectively at the client matter risk assessment level.
  • Gloucestershire (Stonehouse) | Published: Dec 11, 2025.A fine for £8,426 for failing to conduct Client and Matter Risk Assessments on the majority of files reviewed. The firm was found to be using a generic template that did not address the specific risks of their practice.
  • Oldham (Lancashire) | Published: Dec 11, 2025.A firm was hit with a fine of £11,271 for failing to establish and maintain fully compliant policies and controls over an eight-year period. The SRA noted that the absence of these controls created a potential for harm to the public interest.
  • Surrey (Reigate) | Published: Dec 12, 2025. £2,987 fine for failing to update AML policies and FWRA between 2017 and 2025. Although the firm admitted the breaches early, the SRA emphasised that compliance documents must remain current to be effective.

    The AML Reality Check: It is Strict Liability Now

    The SRA are looking for firms unprepared. Nearly every fine this month was triggered by three core failures:

    • Missing or incomplete Firm-Wide Risk Assessments (FWRA).
    • Reliance on generic templates that were not tailored to the firm's specific work.
    • Outdated AML policies that had not been reviewed or updated for several years.
    The Verdict: If your FWRA is gathering dust or your Client Matter Risk Assessments are one-size-fits-all, you are sitting on a regulatory time bomb.

    Is your firm SRA AML audit-ready? These cases prove that the SRA is shifting from checking for existence to testing for effectiveness. Proactive compliance is now the only way to avoid the crackdown trend.

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