For a sole practitioner or the MLRO in a small high-street firm, "AML compliance" often feels like just another mountain of paperwork standing between you and your actual work. When you are juggling a heavy conveyancing caseload, a sensitive probate matter, and the day-to-day survival of your practice, the last thing you need is a new regulator with a reputation for being data-heavy and "zero-tolerance."
But the ground is shifting. As the Financial Conduct Authority (FCA) takes over AML supervision from the SRA, the "high-street way" of doing things—relying on long-standing local reputations and gut instinct—is being replaced by a requirement for hard, documented proof.
The end of "I’ve known them for years"
In a small town, you often act for the same families for generations. You know their business, their parents, and their reputation. Under the old mindset, that felt like enough. Under the FCA, it isn’t.
The FCA supervises on evidence, not relationships. The FCA AML auditor won’t care that a client is a pillar of the community; they will care whether you documented a Source of Wealth check that explains how that community pillar actually acquired their funds. For a busy practitioner, this means the "mental note" must become a digital or paper trail. If it isn't written down, it didn't happen.
Moving past the "Tick-Box" trap
Many small firms use generic AML templates to save time. It’s understandable—you don’t have a dedicated compliance department to draft bespoke manuals. However, the FCA is famously allergic to "copy-paste" compliance.
Your Firm-Wide Risk Assessment needs to smell like your office. If you do 80% conveyancing, your FWRA shouldn't look like it belongs to a firm with a completely different profile. It needs to address the specific struggles you face: high-volume property flips, "gifted deposits" from overseas relatives, or the sudden appearance of cash in a probate estate. The FCA wants to see that you’ve actually thought about the specific risks walking through your door.
The "Sole Practitioner" burden
If you are a sole practitioner, you are the fee-earner, the manager, and now, the person the FCA holds personally accountable. There is no "compliance team" to hide behind.
The struggle here is capacity. The FCA expects the person in charge to have a "defensible" reason for every decision:
- The SARs Dilemma: Filing a Suspicious Activity Report (SAR) on a long-term client feels like a betrayal; not filing one is a regulatory landmine. The FCA expects a recorded "reason why not" if you decide a red flag was a false alarm.
- Ongoing Monitoring: It’s easy to check ID at the start. It’s much harder to notice when a matter starts drifting off-course six months later. The new expectation is active oversight throughout the life of the file.
Making it work on a high-street budget
The shift to FCA supervision likely means more data requests and more formal inspections. You don’t need a six-figure software suite, but you do need a system that works while you’re busy:
- Document the "Why": When you decide a client is low-risk, write one sentence explaining why Do you hvae good technology or a way of recording client matter risk assessments.
- Standardise the "Hard" Questions: Make asking for bank statements a standard part of your Terms of Business so it’s a firm-wide rule, not a personal judgment call.
- Protect Your Time: Use the transition to tighten onboarding. A little extra time spent verifying source of funds at the start can save weeks of stress during a regulatory audit later.
The transition to the FCA is a "professionalisation" of AML. It’s a move away from the informal toward the deliberate. For the high-street firm, the goal isn't to become a corporate giant—it's to ensure that when the regulator knocks, you can show them a practice that is as disciplined as it is dedicated to AML compliance.
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