Macmillans Solicitors LLP
Manor House, Bridgend, WADEBRIDGE , PL27 6BS
Recognised body
596654

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 16 June 2026

Published date: 19 June 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

Agreed outcome

Macmillians Solicitors LLP (the Firm), a Recognised body, authorised and regulated by the Solicitors Regulation Authority (SRA), agrees to the following outcome to the investigation:

• it will pay a financial penalty in the sum of £1,852, under Rule 3.1(b) of the SRA Regulatory and Disciplinary Procedure Rules;
• to the publication of this agreement, under Rule 9.2 of the SRA Regulatory and Disciplinary Procedure Rules; and
• it will pay the costs of the investigation of £600, under Rule 10.1 and Schedule 1 of the SRA Regulatory and Disciplinary Procedure Rules.

Summary of Facts

We carried out an investigation into the firm following a desk-based review (DBR) by our AML Proactive Supervision Team.

Our DBR identified areas of concern in relation to the firm's compliance with the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017 (MLRs 2017), the SRA Principles 2011, the SRA Code of Conduct 2011, the SRA Principles [2019], and the SRA Code of Conduct for Firms [2019].

Firm-wide risk assessment (FWRA)

The firm failed to maintain a compliant FWRA of the risks of money laundering and terrorist financing to which its business was subject too, pursuant to Regulations 18(4) and 18(6) of the MLRs 2017. The firm subsequently provided its newly implemented FWRA dated June 2025, which the DBR assessed as compliant.

Policies, controls, and procedures (PCPs)

The firm's AML PCPs were repeatedly found to be deficient between 2017 and 2025, despite assurances of updates. Reviews identified that earlier PCPs were incomplete and non‑compliant with Regulation 19 of the MLRs 2017. The firm subsequently provided updated PCPs dated June 2025, which the DBR assessed as compliant.

Allegations

Between 26 June 2017 and 16 June 2025, the firm failed to maintain a compliant assessment of the risks of money laundering and terrorist financing to which its business was subject (a firm-wide risk assessment (FWRA)), pursuant to Regulations 18(4) and 18(6) of the MLRs 2017.

Between 26 June 2017 and 1 June 2025, the firm failed to maintain compliant policies, controls, and procedures (PCPs), updating and reviewing the same, to mitigate and manage effectively the risks of money laundering and terrorist financing, identified in any risk assessment (FWRA), pursuant to Regulation 19(1)(b) of the MLRs 2017.

Admissions

The firm admits, and the SRA accepts, that by failing to comply with the MLRs 2017 that it breached:

To the extent the conduct took place before 24 November 2019:

Principle 6 of the SRA Principles 2011 – which states you must behave in a way that maintains the trust the public places in you and in the provisions of legal services.

Principle 8 of the SRA Principles 2011 – which states you must run your business or carry out your role in the business effectively and in accordance with proper governance and sound financial risk management principles.

And the firm failed to achieve:

• Outcome 7.2 of the SRA Code of Conduct 2011 – which states you have effective systems and controls in place to achieve and comply with all the principles, rules and outcomes and other requirements of the handbook, where applicable.
• Outcome 7.3 of the SRA Code of Conduct 2011 – which states you must achieve these Outcomes: you identify, monitor, and manage risks to compliance with all the Principles, rules and outcomes and other requirements of the Handbook, if applicable to you, and take steps to address issues identified.
• Outcome 7.5 of the SRA Code of Conduct 2011 – which states you comply with legislation applicable to your business, including anti-money laundering and data protection legislation.

To the extent the conduct took place from 25 November 2019 onwards:

• Principle 2 of the SRA Principles 2019 – which states you act in a way that upholds public trust and confidence in the solicitors' profession and in legal services provided by authorised persons.
• Paragraph 2.1(a) of the SRA Code of Conduct for Firms 2019 – which states you have effective governance structures, arrangements, systems, and controls in place that ensure you comply with all the SRA's regulatory arrangements, as well as with other regulatory and legislative requirements, which apply to you.
• Paragraph 2.2 of the SRA Code of Conduct for Firms – which states you keep and maintain records to demonstrate compliance with your obligations under the SRA's regulatory arrangements.
• Paragraph 3.1 of the SRA Code of Conduct for Firms 2019 – which states that you keep up to date with and follow the law and regulation governing the way you work

Why a fine is an appropriate outcome

The SRA's Enforcement Strategy sets out its approach to the use of its enforcement powers where there has been a failure to meet its standards or requirements.

When considering the appropriate sanctions and controls in this matter, the SRA has taken into account the admissions made by the firm and the following mitigation:

• There has been no evidence of harm to consumers or third parties and there is a low risk of repetition.
• The firm has assisted the SRA throughout the investigation and has shown remorse for its actions.
• The firm did not financially benefit from the misconduct.

The SRA considers that a fine is the appropriate outcome because:

• The conduct demonstrated a failure to comply with its statutory and regulatory obligations and created a risk of harm by potentially facilitating suspicious transactions linked to money laundering and/or terrorist financing. These AML control deficiencies exposed the firm to heightened risk, particularly in conveyancing, a recognised high-risk area, and could have been mitigated had compliant FWRAs and PCPs been maintained since June 2017.
• It was incumbent on the firm to meet the requirements set out in the MLRs 2017. The firm failed to do so. The public would expect a firm of solicitors to comply with its legal and regulatory obligations, to protect against these risks as a bare minimum.
• The agreed outcome is a proportionate outcome in the public interest because it creates a credible deterrent to others and the issuing of such a sanction signifies the risk to the public, and the legal sector, that arises when solicitors do not comply with anti-money laundering legislation and their professional regulatory rules.
• Rule 4.1 of the Regulatory and Disciplinary Procedure Rules states that a financial penalty may be appropriate to maintain professional standards and uphold public confidence in the solicitors' profession and in legal services provided by authorised persons. There is nothing within this Agreement which conflicts with Rule 4.1 of the Regulatory and Disciplinary Rules and on that basis, a financial penalty is appropriate.

Amount of the fine

The amount of the fine has been calculated in line with the SRA's published guidance on its approach to setting an appropriate financial penalty (the Guidance).

Having regard to the Guidance, the SRA, we, and the firm agree that the nature of conduct in this matter is less serious (score of one). This is because, although the firm's failed to ensure it had compliant AML control documentation in place, in breach of its regulatory obligations, there are mitigating factors. In particular, the firm had instructed an external consultancy to assist in putting in place a compliant FWRA and PCPs prior to the DBR.

We also note that the firm has undertaken a fair proportion of high-risk work since 2017 and continues to do so (currently comprising approximately 35% residential conveyancing and 8% commercial conveyancing). Against that background, the firm's steps to put compliant AML controls in place prior to our DBR, indicates that the conduct did not continue once it was recognised as improper and therefore did not form part of a pattern of behaviour. Furthermore, we note that, following the DBR, the firm did not require any further remedial work on its AML documents, which demonstrates current compliance with the MLRs 2017.

The firm's breach has arisen because of a failure to pay sufficient regard to money laundering regulations, published guidance, and SRA warning notices. The firm failed to ensure that it was fully compliant with its statutory obligations until June 2025, a period of over seven years since the MLRs 2017, came into force.

Consequently, the firm has failed to meet the requirements of the regulations since June 2017, while carrying a higher proportion of work that falls within scope of the MLRs 2017.

The firm has now, compliant documents in place, which are in use, therefore the firm has reduced its vulnerability to ML and CTF risk. Subsequently the SRA considers the overall impact amounts to a lower risk.

The impact of harm or risk of harm is assessed as low (score of two). This is because although there is no evidence that actual harm occurred because of the firm operating without compliant Regulation 18 and Regulation 19 documentation until June 2025, the deficiency nevertheless created a potential risk. We note there were no breaches identified at file level, for instance there were no breaches under Regulation 28(12) and (13) and Regulation 11(a) of the MLRs 2017. Whilst the firm's FWRA and PCPs were found not to comply with the requirements of the MLRs 2017, the SRA acknowledges that no breaches were identified at file level from the sample it reviewed. There was no evidence of deficiencies in client due diligence, ongoing monitoring or source of funds enquiries in the matters reviewed, nor any evidence that the firm had facilitated money laundering or terrorist financing. The firm's non-compliance related to deficiencies in its documented AML framework rather than identified failures in the implementation of AML controls on client matters.

Given the consistently high proportion of in-scope work undertaken by the firm since 2017 to date, the absence of compliant PCPs, would expose the firm to a real potential for harm, including inadequate risk assessment and ineffective mitigation of money laundering risks. Considering the controls in place at file level, there was a potential to cause no more than minimal loss or having no more than a minimal impact and therefore, a score of two is justified and proportionate.

The 'nature' of the conduct and the 'impact of harm or risk of harm' added together give a score of three. This places the penalty in Band “A,” as directed by the Guidance, which indicates a broad penalty bracket of between 0.2% and 0.3% of the firm's annual domestic turnover.

Based on the evidence the firm has provided of its annual domestic turnover; this results in a basic penalty of £2,646.

The SRA considers that the basic penalty should be reduced to £1,852. This reflects the firm's transparency and cooperation with the AML Proactive Supervision team and AML Investigations team, along with putting in place compliant AML documents prior to the DBR admitting and thus remedying the firm's breaches.

The firm does not appear to have made any financial gain or received any other benefit as a result of its conduct. Therefore, no adjustment is necessary, and the financial penalty is £1,852.

Publication

Rule 9.2 of the SRA Regulatory and Disciplinary Procedure Rules states that any decision under Rule 3.1 or 3.2, including a Financial Penalty, shall be published unless the particular circumstances outweigh the public interest in publication.

The SRA considers it appropriate that this agreement is published as there are no circumstances that outweigh the public interest in publication, and it is in the interest of transparency in the regulatory and disciplinary process.

Acting in a way which is inconsistent with this agreement

The firm agrees that it will not deny the admissions made in this agreement or act in any way which is inconsistent with it.

If the firm denies the admissions, or acts in a way which is inconsistent with this agreement, the conduct which is subject to this agreement may be considered further by the SRA. That may result in a disciplinary outcome or a referral to the Solicitors Disciplinary Tribunal on the original facts and allegations.

Acting in a way which is inconsistent with this agreement may also constitute a separate breach of Principles 2 and 5 of the Principles and paragraph 3.2 of the Code of Conduct for Firms.

Costs

The firm agrees to pay the costs of the SRA's investigation in the sum of £600. Such costs are due within 28 days of a statement of costs due being issued by the SRA.