GILL & CO

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 11 February 2026

Published date: 27 February 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

1. Agreed outcome

1.1 Gill & Co (the firm), a recognised body authorised and regulated by the Solicitors Regulation Authority (SRA) agrees to the following outcome to the investigation:

1. the firm is fined £9,380 under Rule 3.1 (b) of the SRA Regulatory and Disciplinary Procedure Rules (RDPRs)
2. to the publication of this agreement under Rule 9.2 of the RDPRs
3. the firm will pay the costs of the investigation of £600, under Rule 10.1 and schedule 1 of the RDPRs.

2. Summary of Facts

2.1 We carried out an investigation into the firm following a 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 the SRA Code of Conduct for Firms (2019).

3. Allegations

3.1 The firm failed to conduct client and matter risk assessments as required by Regulation 28(12)(a)(ii) and Regulation 28(13) of the MLRs 2017.

3.2 In two files of six reviewed, the firm insufficiently conducted ongoing monitoring, including scrutiny of transactions (including, where necessary, the customer’s source of funds), as required by Regulation 28(11)(a) of the MLRs 2017.

3.3 Between 26 June 2017 and July 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 considering all risk factors pursuant to Regulation 18(2) of the MLRs 2017.

3.4 Between 26 June 2017 and July 2024, the firm failed to establish and maintain policies, controls, and procedures (PCPs) to mitigate and effectively manage the risks of money laundering and terrorist financing, identified in any risk assessment (FWRA), pursuant to Regulation 19(1)(a) of the MLRs 2017, and regularly review and update them pursuant to Regulation 19(1)(b) of the MLRs 2017.

4. Admissions

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

4.2 To the extent the conduct took place 26 June 2017 and 24 November 2019:

1. Outcome 7.2 of the SRA Code of Conduct 2011 - 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.
2. Outcome 7.5 of the SRA Code of Conduct 2011 - You comply with legislation applicable to your business, including anti-money laundering and data protection legislation.
3. Principle 6 of the SRA Principles 2011 - You must behave in a way that maintains the trust the public places in you and in the provision of legal services.
4. Principle 8 of the SRA Principles 2011 - 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.

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

5. Paragraph 2.1(a) of the SRA Code of Conduct for Firms - 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.
6. Paragraph 3.1 of the SRA Code of Conduct for Firms - You keep up to date with and follow the law and regulation governing the way you work.
7. Principle 2 of the SRA Principles - You act in a way that upholds public trust and confidence in the solicitors' profession and in legal services provided by authorised persons.

5. Why a fine is an appropriate outcome

5.1 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.

5.2 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. there is no evidence of harm to consumers, or third parties, and our view is that the risk of repetition is low
2. the firm brought itself into compliance by revisiting all active matters in scope and completing a CMRA, and training fee earners on how to complete a CMRA. Training was also provided to fee earners regarding SoF checks and scrutiny. The firm have also put in place effective PCPs and an effective FWRA.
3. the firm has cooperated with the SRA’s AML Proactive Supervision and AML Investigations teams.

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

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). The AML control failings identified as part of this investigation are necessary requirements to help mitigate against these risks.
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 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. 

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.

6.2 We have assessed the nature of conduct in this matter as more serious (a score of three).

6.3 There has been a requirement to have a compliant FWRA since the MLRs 2017 came into force on 26 June 2017, and for these to be regularly updated and maintained in writing. Without a compliant FWRA, the firm cannot identify or mitigate money laundering risks posed to them. This in turn will impact the ability to identify risks on the CMRAs (though in this case they were not being completed). Especially as regulation 28(12) stipulates that a firm’s FWRA needs to be taken into account when assessing risk at file level.

6.4 Additionally, the firm did not update their policy between 2004 and 2024 and thusly did not have a regulation 19 MLR 2017 PCPs document for six years. The 2024 PCPs document was found to have been missing a number of requirements.

6.5 Further there were SoF breaches on two files. It is the SRA’s case that scrutiny of source of funds would always be ‘necessary’ in any transaction relating to the purchase of property, by raising further questions as to how the client had generated/accumulated the funds. There is the risk that the purchase funds are the proceeds of criminal activity.

6.6 The firm should have been ensuring compliance with its obligation to complete CMRAs. There is no evidence the firm have been assessing AML risk at file level.

6.7 The harm or risk of harm is assessed as being medium (a score of four) because the firm failed to have important AML controls in place, and those that were in place were found to be ineffective.

6.8 The above allegations put the firm at risk of being used to launder money. This is especially serious considering the firm conduct a high volume of in-scope work, including high-risk sectors, such as conveyancing.

6.9 Further, PCPs should be informed by the FWRA. It is clear in this case how an inadequate FWRA impacted the firm’s PCPs.

6.10 The 2024 PCPs were missing SoF/source of wealth, and the firm’s approach to risk assessing clients and matters. In this way, the insufficient PCPs has impacted the client files.

6.11 The SRA and the firm agree that a basic penalty towards the higher end of the bracket to be appropriate.

6.12 Based on the evidence the firm has provided of its annual domestic turnover for the most recent tax year; this results in a basic penalty of £10,422.

6.13 The SRA considers that the basic penalty should be reduced to £ £9,380. This reduction reflects the mitigation set out in paragraph 5.2 above.

6.14 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 £9,380.

7. Publication

7.1 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.

7.2 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.

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

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

8.2 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.

8.3 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.

9. Costs

9.1 The firm agrees to pay the costs of the SRA's investigation in the sum of £600.

The date of this Agreement is 11 February 2026