Should I report a minor AML breach to the SRA?

I’m a money laundering officer. On a file review, I found we did not carry out customer due diligence on the beneficial owner of a company for a straightforward conveyancing matter with no AML concerns. Should I report this to the SRA?

The Solicitors Regulation Authority (SRA) requires you to report any serious breaches.

You should review your past file reviews/audits in order to see if there are any similar breaches which lead to a pattern.

If you conclude this is a one-off breach limited in scope and impact, you do not need to report. However, you should record it for compliance purposes.

The SRA’s anti-money laundering (AML) guidance – reporting breaches states:

“The principles of what could constitute serious breaches of the Money Laundering Regulations are as follows (this is not an exhaustive list):

  • intentional or reckless breaches of legal requirements in relation to applicable anti-money laundering legislation or regulation
  • systemic regulatory breaches associated with a failure of AML-related policies, controls or procedures
  • the facilitation of business activities which bear the hallmarks of money-laundering activity (this does not replace the legal requirement to file a SAR where appropriate)

You do not need to report one-off breaches of the regulations which are limited in scope and impact.”

For further information, see the SRA’s guidance on reporting AML breaches.


While every effort has been made to ensure the accuracy of the information in this article, it does not constitute legal advice and cannot be relied upon as such. The Law Society does not accept any responsibility for liabilities arising as a result of reliance upon the information given.

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