Rooks Rider Solicitors LLP
Dowgate Hill House, 14-16 Dowgate Hill, London , EC4R 2SU
Recognised body
559363

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 20 June 2026

Published date: 23 June 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

1. Agreed outcome

1.1 Rooks Rider Solicitors LLP (the firm), a Recognised body authorised and regulated by the Solicitors Regulation Authority (SRA), agrees to the following outcome to the investigation:

1. to pay a financial penalty in the sum of £25,000 under Rule 3.1(b) of the SRA Regulatory and Disciplinary Procedure Rules,
2. to the publication of this agreement under Rule 9.2 of the SRA Regulatory and Disciplinary Procedure Rules, and
3. to 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 a desk-based review (DBR) 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 previously 2011) the SRA Code of Conduct for Firms 2019 (and previously 2011).

Firm – wide risk assesemnts (FWRA)

2.3 On 2 June 2025, the firm was asked to provide its FWRA as part of a 'pre-inspection questionnaire'. On 3 June 2025, the firm sent its AML documents (including its FWRA) and written responses to the questionnaire asking when the firm first implemented a FWRA

2.4 The firm provided all historic copies of its FWRA, as well as the one that was in current use (dated 16 February 2024).

2.5 Upon review of the firm's previous FWRA the Investigation Officer concluded that none of the earlier versions (prior to 2024) were compliant with Regulation 18. This is because, the documents failed to identify and address the five key risk factors as set out in Regulation 18(2)(b).

2.6 Therefore, it is the case that between 26 June 2017 and 16 February 2024, 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 MLRs 2017. Policies, controls and procedures (PCPs)

2.7 On 2 June 2025, the firm was asked to provide its PCPs as part of the 'pre-inspection questionnaire'. On 3 June 2025, the firm sent its AML documents (including its PCPs) and written responses to the questionnaire asking when the firm first implemented its PCPs.

2.8 The firm provided all historic copies of its PCPs as well as the one that was in current use (dated 29 January 2022).

2.9 Upon review of these documents, it was clear that the firm had PCPs (formally P&Ps under Money laundering regulations 2007) in place in 2012, but these were not updated until 29 January 2022.

2.10 The firm's PCPs were not compliant with the MLRs 2017 as the document was relying on the previous versions of the MLRs (2007) and therefore did not contain enough detail on many of the sections mandated by Regulation 19. The document did not contain any reference to the MLRs 2017 and contained many outdated references to historic legislation.

2.11 Therefore, it is the SRAs case that between 26 June 2017 and 29 January 2022 the firm failed to establish and maintain 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.

Source of funds (SoF)

2.12 As part of the DBR six files were requested, including all client due diligence and SoF documentation. On three out of six of the files, there was inadequate SoF information evidenced.

2.13 All three of these files were residential property purchases and demonstrated a pattern of large sums of money being accepted into the firm's client account without evidence or documentation obtained to establish the source of those funds. Conveyancing is a considered a high-risk area and therefore all files should have contained adequate documentation to show the origin of funds used in the transaction and should be able to demonstrate that any documents obtained had been properly scrutinized

2.14 The firm has since confirmed that training has been provided to all fee earners regarding obtaining the correct SoF information and has demonstrated to the SRA that it is now obtaining and scrutinizing SoF information on files going forward.

2.15 Therefore, it is the SRA's case that on three out of the six files reviewed, the firm failed to conduct 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. Admissions

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

From 26 June 2017 to 24 November 2019 (when the SRA Handbook 2011 was in force), the firm has breached:

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 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 risk management principles

And the firm has failed to achieve

3. Outcome 7.2 of the SRA Code of Conduct 2011 – which states that 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) until June 2025, the firm has 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.

4. Why a fine is approate 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 put in place a compliant FWRA and PCPs prior to the SRA's DBR. Furthermore, the firm was able to exemplify it was now conducting thorough SoF on all relevant files, and training had been provided on this.
2. The firm has cooperated with the SRA's AML Proactive Supervision and AML Investigation teams.

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 the potential to cause harm, by failing to ensure the firm had proper AML control documentation in place and failing to undertake source of funds (SoF), checks in conveyancing transactions, that could have led 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 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.

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 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's failure to ensure it had proper documentation in place shows a persistent disregard of the firm's regulatory obligations. This is more serious given the lack of SoF at file level, resulted in insufficient scrutiny being applied to monies that the firm would have held.

5.3 The breach has arisen because of recklessness and a failure to pay sufficient regard to money laundering regulations, published guidance and SRA warning notices. The firm has failed to ensure that it was fully compliant with its statutory obligations until 2022 (PCPs), 2024 (FWRA) and 2025 (SoF) which shows at the very minimum a period of five years of non- compliance since the MLRs 2017 came into effect.

5.4 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. The firm currently undertakes nearly all of its work in-scope of the money laundering regulations, with around 25% of this being conveyancing work. However, there is no evidence of there being any direct loss to clients or any further harm as a result of the firm's failure to ensure it had proper documentation in place and despite not conducting necessary SoF checks at file level.

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

5.6 We and the firm agree a financial penalty at the lower end of the bracket. Although the firm lacked a compliant AML control environment for several years, the firm was able to demonstrate that it had brought itself in to compliance on its own accord (in respect of its FWRA/PCPs) and is now able to demonstrate that it is carrying out the correct SoF check on all files going forward.

5.7 Based on the evidence the firm has provided of its annual domestic turnover, this results in a basic penalty of £36,300.

5.8 The SRA considers that the basic penalty should be reduced to £25,000. This reduction reflects the mitigation (20%) set out at paragraph 4.2 above and the SRA's discretion permitted in the Guidance to cap the fine.

5.9 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 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

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 1, 2 and 5 of the SRA 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 within 28 days of a statement of costs due being issued by the SRA.

The date of this Agreement is 20 May 2026