CD&R Galaxy Opco Limited
3 More London Riverside, London , SE1 2AQ
Licenced body
839727

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 19 December 2025

Published date: 29 December 2025

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

1. Agreed outcome

2. CD&R Galaxy UK Opco Limited (the firm), a Licensed Body, authorised and regulated by the Solicitors Regulation Authority (SRA), agrees to the following outcome to the investigation:

1. it will pay a financial penalty in the sum of £33,438
2. to the publication of this document, and
3. it will pay the costs of the investigation of £600.

3. Summary of facts

3.1 We carried out an investigation into the firm following an inspection by our AML Proactive Supervision team.

3.2 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 the SRA Code of Conduct for Firms [2019].

Firm-wide risk assessment (FWRA)

3.3 Between 26 April 2022 and October 2024, the firm failed to have in place a written FWRA in accordance with Regulations 18(1) and 18(4) of the MLRs 2017.

3.4 The firm was asked to provide its FWRA as part of the 'pre-inspection questionnaire'. In response to this, the firm stated that it was in the process of drafting a FWRA and was therefore unable to produce one.

3.5 In a subsequent email, the firm emailed the investigation officer with a FWRA. In the same email, the firm attached previous versions of the document, dating back to October 2024.

3.6 Although we are satisfied the firm now has a compliant FWRA in place and has had an FWRA since October 2024, this has been a requirement since June 2017. Therefore, it is the case that between 26 April 2022 (when the firm started trading) and October 2024, the firm failed to have in place a written FWRA in accordance with Regulations 18(1) and 18(4) of the MLRs 2017.

Client and matter risk assessments (CMRAs)

3.7 As part of the firm's own review, it was found that it had not completed CMRA's on all files pursuant to Regulation 28(12) and Regulation 28(13) of the MLRs 2017.

3.8 Subsequent to our inspection, the firm reviewed its own internal processes and compliance procedures. The review found that some of the files originating from the firm's previous owner did not have a CMRA present or the appropriate level of customer due diligence (CDD).

3.9 The firm self-reported this to us on 27 May 2025 and has kept the SRA up to date with its own investigation and remedial work. The firm has instructed a law firm to remediate the active in-scope files that were not compliant and predicts this will be completed by the end of December 2025.

4. Admissions

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

1. 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.
2. 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.
3. 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.

5. Why a fine is an appropriate outcome

5.1 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.

5.2 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.

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

1. The agreed outcome is proportionate and 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.

5.4 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.

6. Amount of the fine

6.1 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).

6.2 Having regard to the Guidance, we and the firm agree that the nature of the misconduct was more serious (score of three). This is because the firm should have been aware of its obligation to have in place a compliant FWRA and to ensure that all files had a CMRA since it began trading in 2022.

6.3 In addition, a significant proportion of the firm's work currently 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.

6.4 The firm has failed to meet the requirements of the regulations since it began trading 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 prior to this, and the SRA considers that this amounts to a serious breach.

6.5 The impact of the harm or risk of harm is assessed as being low (score of two). This is because there is no evidence of any harm being caused, as a result of the firm's breaches. The firm's work, although in scope of the MLRs 2017, is relatively low risk and the firm has instructed assistance in order to remediate the failings identified promptly. Furthermore, the firm is relatively young, and risk of harm is limited to the three years it has been trading.

6.6 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.

6.7 We recommend a basic penalty at the lower end of the bracket. This is because while there were failings which had the potential to cause significant loss or have significant impact, no evidence of actual harm was identified. The firm should have been aware of its statutory obligations under the MLRs 2017, and the breaches spanned the entirety of the firm's lifespan. However, the firm has now brought itself into compliance and therefore the ongoing risk is low.

6.8 Based on the evidence the firm has provided of its annual domestic turnover this results in a basic penalty of £44,585.

6.9 We have considered mitigating factors and it is our view that the basic penalty should be discounted by twenty five percent. This is to take account of the following factors as indicated by the Guidance:

1. Early admission – the firm identified the failings around CMRAs through its own investigation and promptly reported this to us. The firm has kept the SRA updated throughout its own investigation.
2. Remedy of harm – the firm took steps to rectify its non-compliance, by instructing external assistance to remediate the active, in-scope files.
3. Cooperating with the investigation – the firm has cooperated with the SRA's AML Proactive Supervision and AML Investigation teams

6.10 The adjusted penalty is therefore £33,438.

6.11 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 £33,438.

7. Publication

7.1 Section 87(1) of the Legal Services Act 2007 (LSA 2007) and the Registers of licenced bodies: Section 87(4) rules, require the SRA, as a licencing authority, to maintain and publish a register of licenced bodies, which includes information on enforcement action or sanctions imposed on a licenced body, owner or employee of a licenced body.

7.2 This agreement confirms a decision has been made under Section 95 of the LSA 2007 to fine CD&R Galaxy UK Opco Limited, which is a licenced body, which will be published. We do not have any discretion not to publish the decision.

8. Acting in a way which is consistent with this agreement

8.1 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.

8.2 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.

9. Costs

9.1 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.