HMG LAW LLP

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 27 January 2026

Published date: 2 February 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Reasons/basis

1. Agreed Outcome

1.1 HMG Law LLP (the firm), a recognised body, authorised and regulated by the Solicitors Regulation Authority (SRA), agrees to the following outcome to the investigation:

1. HMG Law LLP will pay a financial penalty in the sum of £25,000, 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 Procedures Rules; and
3. HMG Law LLP will pay the costs of the investigation of £600, under Rule 10.1 and Schedule 1 of the SRA Regulatory and Disciplinary Procedures Rules.

2. Summary of Facts

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

2.2 Our inspection and subsequent 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 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)

2.3 Between 17 December 2019 and 29 August 2025, the firm failed to keep an up-to-date record in writing of its assessments of the risks of money laundering and terrorist financing to which its business was subject (a firm-wide risk assessment (FWRA)), pursuant to Regulation 18(4) and Regulation 18(6) of the MLRs 2017.

Policies, controls and procedures (PCPs)

2.4 Between July 2019 and 29 August 2025, the firm failed to regularly review and update its policies, controls, and procedures (PCPs) 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.

2.5 In six files,the firm failed to follow or implement its own PCPs, pursuant to Regulation 19(3)(e) of the MLRs 2017. Client and matter risk assessments (CMRAs)

2.6 In six files, the firm failed to conduct client and matter risk assessments (CMRAs), pursuant to Regulation 28(12)(a)(ii) and Regulation 28(13) of the MLRs 2017.

3. Admissions

3.1 The firm admits, and the SRA accepts, that by failing to comply with the MLRs 2017, it has breached or failed to achieve:

To the extent that the conduct took place on or before 24 November 2019 (when the SRA Handbook 2011 was in force):

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 7 of the SRA Principles 2011 - which states you must comply with your legal and regulatory obligations and deal with your regulators and ombudsmen in an open, timely and co-operative manner.
3. 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 and risk management principles.
4. Outcome 7.2 of the SRA Code of Conduct 2011 - which states you must achieve these Outcomes: 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.
5. 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.
6. Outcome 7.5 of the SRA Code of Conduct 2011 - which states you must achieve these Outcomes: you comply with legislation applicable to your business, including anti-money laundering and data protection legislation.

In so far as the conduct took place from 25 November 2019 onwards (when the SRA Standards and Regulations came into force):

7. Principle 2 of the SRA Principles 2019 - which states you must act in a way that upholds public trust and confidence in the solicitors' profession and in legal services provided by authorised persons.
8. Paragraph 2.1(a) of the SRA Code of Conduct for Firms - which state you must 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.
9. Paragraph 2.2 of the SRA Code of Conduct for Firms - which states you must keep and maintain records to demonstrate compliance with your obligations under the SRA's regulatory arrangements.
10. Paragraph 3.1 of the SRA Code of Conduct for Firms - which states you must keep up to date with and follow the law and regulation governing the way you work.
11. Paragraph 3.3(a) of the SRA Code of Conduct for Firms – which states that you must respond promptly to the SRA and provide full and accurate explanations, information, and documents in response to any request or requirement.

4. Why a fine is an appropriate outcome

4.1 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.

4.2 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:

1. The firm took steps to rectify its failings and is compliant with the MLRs 2017.
2. The firm has cooperated with the SRA’s AML Proactive Supervision and AML Investigation teams.
3. The firm has admitted the breaches listed above at the earliest opportunity.

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

1. The conduct showed a disregard towards statutory and regulatory obligations and had a potential to cause harm by failing to have compliant AML control documentation in place at both firm and file level, which left the firm susceptible to money laundering (and/or terrorist financing).
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.
3. 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.

4.4 Rule 4.1 of the Regulatory and Disciplinary Procedures 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 Procedures 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 We have assessed the nature of conduct in this matter as more serious (score of three). This is because the firm’s failure to ensure it had proper AML control documentation in place shows a persistent disregard of the firm’s regulatory obligations. This is more serious given the lack of CMRA at file level, which translated to a poor understanding of the risks posed by clients and matters and resulted in insufficient scrutiny being applied, and staff failing to follow and implement the firm’s own PCPs.

5.3 The firm only became compliant with the MLRs 2017 because of our AML deskbased review and guidance we have provided. The breach has arisen because of recklessness and a failure to pay sufficient regard to money laundering regulations, published guidance and SRA warning notices.

5.4 The firm has failed to ensure that it was fully compliant with its statutory obligations until 29 August 2025, a period of over eight years since the MLRs 2017 came into effect (notwithstanding the firm’s previous obligations under Regulation 7(3) of the MLRs 2007).

5.5 The impact of the harm or risk of harm is assessed as being medium (score of four). The nature of conveyancing is considered high-risk, owing to the risk of abuse of the system by criminals. We note the firm currently undertakes around two-thirds of its work in scope of the money laundering regulations, via mainly conveyancing. This puts it at a risk of being used to launder money. Conveyancing is a high-risk area for money laundering and terrorist financing, however there is no evidence of there being any direct loss to clients or actual harm caused as a result of the firm’s failure to ensure it had proper documentation in place, and despite policies, controls and procedures not being followed with respect to CMRAs.

5.6 The ‘nature’ of the conduct and the ‘impact of harm or risk of harm’ added together gives a score of seven. This places the penalty in Band “C”, as directed by the Guidance.

5.7 We and the firm agree a financial penalty at the middle of the bracket. This is because, despite the lack of compliance until May 2025, we are pleased to see the firm has updated and amended its FWRA and PCPs, rolled out training to staff on obtaining, documenting and scrutinising SoF checks and completing and documenting CMRAs, reviewed live in-scope files for completed CMRAs, and registered itself as a tax adviser services provider, to ensure ongoing and future compliance.

5.8 Based on the evidence the firm has provided of its annual domestic turnover, this results in a basic penalty of £27,901.

5.9 The SRA considers that the basic penalty should be reduced to £25,000. This reduction reflects the mitigation set out at paragraph 4.2 above and the SRA’s discretion permitted in the Guidance.

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 £25,000.

6. Publication

6.1 Rule 9.2 of the SRA Regulatory and Disciplinary Procedures 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 public.

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 deny the admissions made in this agreement or act in any way which is inconsistent with it.

7.2 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.

7.3 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.

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 immediately following a statement of costs due being issued by the SRA.