Collier Littler LLP
411-413 Stockport Road Timperley Altrincham , WA15 7XR
Recognised body
630425

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 19 March 2026

Published date: 20 March 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

1 Agreed outcome

1.1 Collier Littler LLP, (the Firm), a Recognised Body authorised and regulated by the Solicitors Regulation Authority (SRA), agrees to the following outcome to the investigation:

1. to pay a financial penalty in the sum of £5,687 under Rule 3.1(b) of the SRA Regulatory and Disciplinary Procedures Rules;
2. to the publication of this agreement, under Rule 9.2 of the SRA Regulatory and Disciplinary Procedure rules; and
3. to pay the costs of the investigation of £600, under Rule 10.1 and Schedule 1 of the SRA Regulatory and Disciplinary Rules

2. Summary of Facts

2.1 We carried out an investigation into the firm following a desk-based review by our AML Proactive Supervision team.

2.2 Our investigation 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 2019 (and previously 2011) the SRA Code of Conduct for Firms 2019 (and previously 2011)

Firm-wide risk assessment (FWRA)

2.3 In our letter dated 1 July 2025, the firm was asked to provide its FWRA as part of the ‘pre-inspection questionnaire’. On 10 July 2025, the firm sent its AML documents (including its FWRA) and written responses to the questionnaire.

2.4 The FWRA was reviewed by the AML Officer and AML Investigation Officer, and was deemed to be inadequate, as the majority of the sections lacked detail specific to the firm. Therefore, the document was not tailored to the firm in order to allow it to thoroughly assess the firm’s AML risk profile. Furthermore, some of the information contained within the document was not accurate or outdated.

2.5 The firm was provided with guidance to assist with redrafting a compliant FWRA. On 23 October 2025, the firm sent an email to the SRA attaching a revised FWRA. Upon review, we are satisfied that the firm now has a compliant FWRA in place.

2.6 Therefore, it is the case that Between 26 June 2017 and 23 October 2025, the firm failed to have in place an appropriate FWRA that identified and assessed the risks of money laundering to which it was subject, taking into account all risk factors pursuant to Regulation 18(2) of the MLRs 2017.

Client and Matter Risk Assesments (CMRAs)

2.7 In our letter dated 1 July 2025, the firm was asked to send us its ‘template client and matter risk assessment’, and this was subsequently provided.

2.8 As part of the inspection, six client files were reviewed and on five of these matters, the CMRA was carried out a significant time after the matter commenced. In these five cases, the CMRA was completed following our request to review the file, suggesting a retrospective and reactive approach to assessing risk.

2.9 It is therefore unclear how the firm was effectively assessing risk, if the CMRA was completed retrospectively.

2.10 On 24 October 2025, the firm sent the Investigation Officer an email confirming that all live files within scope of the MLRs 2017 contain a CMRA.

2.11 Therefore, it the SRA’s case that on five out of six files reviewed, the firm failed to assess the level of risk at the outset of the matter as required by Regulation 28(12) and Regulation 28(13) of the MLRs 2017.

3. Admssions

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

From 6 October 2011 to 24 November 2019 (when the SRA Handbook 2011 was in force), the firm has breached:

1. 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 provision of legal services.
2. 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 has failed to achieve:

3. Outcome 7.2 of the SRA Code of Conduct 2011 – which states that 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.
4. 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.

And from 25 November 2019 (when the SRA Standards and Regulations came into force) until June 2025, the firm has breached:

5. 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.
6. 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.
7. 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.

4. Why a fine is an appropriate outcome

4.1 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). This could have been avoided had the firm established adequate AML documentation and controls.

4.2 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.

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

1. 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.
2. There has been no evidence of harm to consumers or third parties and there is now a low risk of repetition.
3. The firm has assisted the SRA throughout the investigation and has shown remorse for its actions.
4. The firm did not financially benefit from the misconduct.

4.4 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.

5. Amount of the fine

5.1 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).

5.2 Having regard to the Guidance, we and the firm agree that the nature of conduct in this matter as more serious (score of three). This is because the firm should have been aware of its obligation to have in place a compliant FWRA since 2017. Further, the firm had obligations to be carrying out a CMRA at the appropriate time on all in-scope files. In addition, a significant proportion of the firm’s work falls within scope of the MLRs 2017, therefore the firm should have been familiar with the obligations imposed by the regulations and should have implemented strict adherence.

5.3 The firm has failed to meet the requirements of the regulations over many years, while carrying a large proportion of work that falls within scope of the regulations. Although the firm now has compliant documents in place, which are in proper use, the firm was left vulnerable for a significant period of time, and the SRA considers this amount to a serious breach.

5.4 The impact of harm or risk of harm score is assessed as being low (score of two). This is because there is no evidence of any harm being caused, because of the firm not having compliant documents in place. There was, however, still a potential to cause harm due to the firm’s percentage of in-scope work and therefore we feel that a score of two is appropriate.

5.5 The ‘nature’ of the conduct and the ‘impact of harm or risk of harm’ added together give a score of five. This places the penalty in band “B” as directed by the Guidance, which indicates a broad penalty bracket of between 0.4% to 1.2% of the firm’s annual domestic turnover.

5.6 We recommend a basic penalty in the middle of the bracket. This is because the firm should have been aware of its statutory obligations under the MLRs 2017. The firm’s breaches were serious, as the firm lacked a compliant mandatory AML document and could not evidence proper use of its CMRA. The breach spanned several years, during which a significant proportion of the firm’s work was in-scope of the regulations. However, the firm has now brought itself into compliance and therefore the ongoing risk is lower.

5.7 Based on the evidence the firm has provided of its annual domestic turnover this results in a basic penalty of £6,319.

5.8 We have also considered mitigating factors and consider that the basic penalty should be discounted by ten percent. This is to take account of the following factors as indicated by the Guidance:

1. Remedy harm – the firm took steps to rectify its breaches and is now fully compliant with the MLRs 2017.
2. Cooperating with the investigation – the firm has cooperated with the SRA’s AML Proactive Supervision and AML Investigation teams

5.9 The adjusted penalty is therefore £5,687.

5.10 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 £5,687.

6. Publication

6.1 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.

6.2 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.

7. Acting in a way which is inconsistent with this agreement

7.1 The firm agrees that it will not act in any way which is inconsistent with this agreement, such as by denying responsibility for the conduct referred to above. This may result in a further disciplinary sanction.

7.2 Acting in a way which is inconsistent with this agreement may also constitute a separate breach of Principles 1, 2 and 5 of the SRA Principles.

8. Costs

8.1 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.