Humphreys & Co
1 King Street, Bristol , BS1 4EF
Recognised body
062944

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 16 January 2026

Published date: 19 January 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

Agreed outcome

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

1. Humphreys & Co is fined £24,922 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. Humphreys & Co will pay the costs of the investigation of £600, under Rule 10.1 and schedule 1 of the RDPRs. 

Summary of Facts

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

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 2011, the SRA Code of Conduct 2011, the SRA Principles [2019] and the SRA Code of Conduct for Firms [2019]. 

Allegations

Between 26 June 2017 and 30 June 2022, the firm failed to establish and maintain in our judgment fully compliant 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.

In six of the eight files reviewed, the firm failed to maintain records of its client and matter risk assessment (CMRA) under Regulation 28 of the MLRs 2017. Therefore, the firm was unable to sufficiently demonstrate that the extent of the measures it had taken to satisfy the requirements of Regulation 28 were appropriate, as required by Regulation 28(16) of the MLRs 2017.

Admissions

The firm admits, and the SRA accepts, that by failing to comply with the MLRs 2017, that it breached, for conduct up to 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 provisions of legal services.  
2. Principle 8 of the SRA Principles 2011 – whichstates you must run in 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:  

3. 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. 
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), the firm 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. 

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 Humphreys & Co and the following mitigation:

1. There is no evidence of any harm to consumers, or third parties, and our view is that the risk of repetition is low. 
2. The firm took steps to rectify its failures and implemented compliant PCPs before our inspection and since the inspection, has ensured that all files in scope of the MLRs 2017 include a completed CMRA. 
3. The firm has cooperated with the SRA's AML Proactive Supervision and AML Investigations teams. 

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 sufficiently. 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.   

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 financia penalty (the Guidance).

Having regard to the Guidance, the SRA and the firm agree that the nature of the misconduct was more serious (score of three). This is because the firm should have taken more care to ensure it had in place fully compliant PCPs and ensured it fully implemented its obligations to complete CMRAs.

The firm undertakes significant amounts of in-scope work and has failed to meet these requirements of the MLRs 2017. Although the firm put in place compliant PCPs prior to our inspection and a compliant CMRA process in June 2022, both client risk and matter risk assessments were not being sufficiently recorded consistently following the introduction of the regulations, thus, demonstrating a persistent disregard for its regulatory obligations.

The SRA considers, and the firm agrees, that the impact of the misconduct was medium (score of four). This is because the firm had failed in its duties under multiple aspects of the MLRs 2017 which left it particularly vulnerable to the risks of money laundering. These risks are heightened when considering that a fifth of the firm's turnover compromises conveyancing work, which is a high-risk area in regards to the potential for abuse by criminals.

The nature and impact scores add up to seven. This places the penalty in Band 'C' as directed by the guidance.

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

Based on the evidence the firm has provided of its total annual domestic turnover for 2024/2025; this results in a basic penalty of £31,152.

The SRA considers that the basic penalty should be reduced to £24,922. This reduction reflects the mitigation set out in paragraph 5.2 above.

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 £24,922.

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.