Knipe Woodhouse-Smith
145-147 High Street, Chalfont St. Peter, Gerrards Cross , SL9 9QL
Recognised body
487314

Decision - Fined

Outcome: Fine

Outcome date: 31 July 2026

Published date: 7 September 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by SRA decision.

Decision details

Who does this disciplinary decision relate to?

Knipe Woodhouse-Smith, which is a recognised body whose offices are at 145-147 High Street, Chalfont St Peter, Gerrards Cross SL9 9QL.

Summary of decision

The firm was fined for failing to ensure it had relevant documentation in place to prevent activities relating to money laundering and terrorist financing as required by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017).

Facts of the misconduct

In July 2024, the SRA's Anti-Money Laundering (AML) proactive supervision team undertook a desk-based review (DBR) to assess the firm's compliance with the MLR 2017.

On 8 October 2024, an SRA AML officer communicated the outcome of the DBR. Concerns were raised surrounding the firm's compliance with requirements for a documented and compliant firm wide risk assessment (FWRA) policies, controls and procedures (PCPs) and completion of client matter risk assessments (CMRA) on files.

These concerns led to a referral to the SRA's AML investigation team. The firm was provided with guidance to help it come into compliance. On 23 October 2024, the firm entered into a compliance plan in which it agreed to take steps to demonstrate its compliance with the MLR 2017 by 3 December 2024. The firm failed to comply.

Thereafter, the SRA requested that the firm take steps to remedy the deficiencies identified by complying with the compliance plan and by producing the requested AML information and documentation. The firm failed to respond or act promptly in response to repeated requests for it to comply or promptly take remedial action. It failed to comply or produce fully compliant AML documentation until 10 April 2026.

Findings

It was found that:

Allegation 1a

Between 26 June 2017 and March 2023, the firm failed to have in place a documented assessment of the risks of money laundering and terrorist financing to which its business was subject (a FWRA) pursuant to Regulation 18(1) and 18(4) of the MLR 2017.

Allegation 1b

Between March 2023 and April 2026, 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 MLR 2017.

Allegation 2a

Between 26 June 2017 and March 2023, 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 MLR 2017.

Allegation 2b

Between March 2023 and April 2026, the firm failed to establish and maintain fully compliant 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 MLR 2017.

Allegation 3a

In three of six files reviewed for the DBR, the firm failed to conduct client and matter risk assessments as required by Regulation 28(12)(a)(ii) and Regulation 28(13) of the MLR 2017.

Allegation 3b

In three of six files reviewed for the DBR, the firm failed to sufficiently assess the level of risk, as required by Regulation 28(12) and Regulation 28(13) of the MLR 2017.

In doing so, in respect of the above allegations, to the extent the conduct took place before 24 November 2019, the firm:

1. breached Principles 6 and 8 of the SRA Principles 2011, and
2. failed to achieve Outcomes 7.2 and 7.5 of the SRA Code of Conduct 2011 and to the extent the conduct took place from 24 November 2019, the firm breached:
3. Principle 2 of the SRA Principles 2019, and
4. Paragraphs 2.1(a), 3.1 and 3.3(a) of the SRA Code of Conduct for Firms 2019

Allegation 4

Between 8 October 2024 and 10 April 2026, the firm failed to cooperate with, respond promptly to, promptly provide information and documentation, and promptly take remedial action requested by the SRA.

In doing so the firm breached:

1. Principle 2 of the SRA Principles 2019, and
2. Paragraphs 3.2, 3.3 and 3.4 of the SRA Code of Conduct for Firms (2019).

Decision on sanction

The firm was directed to pay a financial penalty of £8,211 and ordered to pay costs of £1,350. This was because the firm's conduct was serious by reference to the following factors in the SRA Enforcement Strategy:

1. The findings relate to breaches of the MLR 2017, which protect the public from the serious consequences of money laundering and terrorist financing.
2. The firm's conduct was a breach of its legislative and regulatory obligations which persisted for longer than was reasonable. It demonstrated a pattern of non-compliance.
3. The firm was responsible for its own conduct which was serious and had the potential to cause harm to the public interest and to public confidence in the legal profession. This risk was heightened given the high proportion of the firm's work that was ‘in scope' of the MLR 2017.

In view of the above, the firm's conduct was placed in conduct band C which has a financial penalty of 1.6 per cent to 3.2 per cent of annual domestic turnover. The firm's conduct was placed in the mid-range of this band at C3 (2.4 per cent of annual domestic turnover).

SRA Standards and Regulations breached

SRA Principles 2011

Principle 6

You must behave in a way that maintains the trust Solicitors Regulation Authority Limited the public places in you and in the provision of legal services.

Principle 8

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.

SRA Principles 2019

Principle 2

You act in a way that upholds public trust and confidence in the solicitors' profession and in legal services provided by authorised persons.

SRA Code of Conduct 2011

Outcome 7.2

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.

Outcome 7.5

You comply with legislation applicable to your business, including anti-money laundering and data protection legislation.

SRA Code of Conduct for Firms 2019

Paragraph 2.1(a)

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.

Paragraph 3.1

You keep up to date with and follow the law and regulation governing the way you work. Paragraph 3.2

You cooperate with the SRA, other regulators, ombudsmen and those bodies with a role overseeing and supervising the delivery of, or investigating concerns in relation to, legal services.

Paragraph 3.3

You respond promptly to the SRA and:

1. provide full and accurate explanations, information and documentation in response to any requests or requirements;
2. ensure that relevant information which is held by you, or by third parties carrying out functions on your behalf which are critical to the delivery of your legal services, is available for inspection by the SRA.

Paragraph 3.4

You act promptly to take any remedial action requested by the SRA.