The Solicitors Regulation Authority (SRA) has fined the conveyancing firm, Ferguson Bricknell Solicitors, £20,000 ($24,400) for falling short of its anti-money laundering (AML) obligations. The firm also had to pay £1,350 for the cost of the SRA probe. The fine was issued under a regulatory settlement agreement following an investigation by the SRA.

The investigation found that the firm did not have a compliant, practice-wide, anti-money laundering (AML) risk assessment in place until July 29, 2022, and also failed to fully assess its product/services risks, specifically those associated with conveyancing and controlling client money, which accounted for 75% of its fee income. The risks associated with conveyancing should have been addressed in the assessment provided when the investigation began.

The SRA further noted that Ferguson Bricknell’s risk assessment “failed to have sufficient regard” for AML guidance issued by the Legal Sector Affinity Group (LSAG) in 2018. The SRA highlighted that:

  • Ferguson Bricknell had failed to establish an adequate practice-wide risk assessment based on guidance from the Legal Sector Affinity Group (LSAG)
  • The firm did not have compliant AML policies, controls and procedures in place until 1 August 2022, despite warning notices issued by the SRA
  • They had breached Regulation 21(1)(c) of the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017 by not establishing an independent audit function
  • They had not provided proper training on the money laundering rules to all relevant employees and had not maintained training records for its employees, and one of the partners had not had any training on the Money Laundering Regulations 2017 (MLRs 2017)
  • The money laundering reporting officer had not done any additional training to support staff in their roles 
  • Employees were given a booklet in January 2022, but it was five years out of date

The SRA stated that “the conduct showed a disregard for statutory and regulatory obligations and had the potential to cause harm, by facilitating dubious transactions that could have led to money laundering (and/or terrorist financing)”. The regulator did note that there had been no evidence of harm to consumers or third parties and that Ferguson Bricknell did not benefit financially from the misconduct. The firm had also assisted the SRA with its investigation and recognized that it failed in its basic duties on statutory money laundering regulations and regulatory requirements.

This case underlines the importance of ongoing training, an efficient and up-to-date onboarding and monitoring system, and expertly executed independent audits to ensure compliance with AML regulations. 

How VinciWorks can help 

AML onboarding solution

Omnitrack, VinciWorks’ AML client onboarding solution enhances both the risk assessment and document collection aspects of client onboarding. Our template workflows adapt to the specific risks posed by each client, based on factors such as jurisdiction, type of entity and industry. This allows you to make informed choices about each client using the risk-based approach. Our comprehensive workflows incorporate industry-specific guidance such as LSAG for law firms.


VinciWorks’ anti-money laundering training gives users the most up-to-date and comprehensive understanding of AML rules and regulations. Our LMS enables you to administer, manage and automate a full AML compliance and learning plan and maintain training records.

Independent audits with Compliance Office

Our partners at Compliance Office have the expertise needed to help you conduct an independent AML audit in accordance with the latest Legal Sector Affinity Group (LSAG) guidance. Their team stays on top of the latest AML requirements and your audit will often be administered by former SRA staff. 

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