Vincents Solicitors LTD
Guild Chambers, 4 Winckley Square, Preston , PR1 3JJ
Recognised body
596640

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 22 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 Vincents Solicitors LTD (the Firm), a recognised body agrees to the following outcome to the investigation of its conduct by the Solicitors Regulation Authority (SRA):

1. it is rebuked
2. to the publication of this agreement
3. it will pay the costs of the investigation of £600.

2. Summary of Facts

2.1 A desk-based review (DBR) was carried out at the firm by our AML Proactive Supervision team. The DBR identified an AML control failing in that seven of the eight files reviewed did not contain a client and matter risk assessment (CMRA). As a result, the firm was referred for investigation.

2.2 Regulations 28(12) and 28(13) of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017), require firms to take steps to identify the money laundering and terrorist financing risks posed by a particular customer (or 'client') and matter – the CMRA.

2.3 The firm confirmed to the SRA that the firm's process for risk assessing clients and matters was introduced on 12 July 2024. The Investigation Officer therefore queried what the firm's process was prior to this date in order to meet the requirements of Regulation 28 of the MLRs 2017. The firm confirmed it was using a 'risk assessment form'.

2.4 The firm provided a copy of the aforementioned risk assessment form and this was found to be non-compliant with Regulation 28 of the MLRs 2017. For example, the form did not stipulate the level of due diligence that was appropriate or have scope to identify the high-risk factors identified under Regulation 18(1) of the MLRs 2017.

2.5 We therefore determined that:

• Between 26 June 2017 and 12 July 2024, Vincents Solicitors LTD 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. Admissions

3.1 Vincents Solicitors Limited makes the following admissions, which we accept, 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.

From 25 November 2019 (when the SRA Standards and Regulations came into force) until July 2024 it 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 written rebuke 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 identified at an early stage in 2024 (prior to the knowledge of a review by the SRA), that it's approach to CMRAs required updating to ensure continued compliance with its obligations. A structured review identified areas where clarification and enhancement were required. We are satisfied that the firm took appropriate measures to adapt this process before the SRA became involved, and is now adequately assessing client and matter risk.
2. The firm demonstrated a good insight into the requirements of Regulations 18 and 19 of the MLRs 2017 given that only minor guidance was provided following the desk-based review. This mitigates the potential risk of harm despite the lack of risk assessments at client and matter level between 26 June 2017 and 12 July 2024.
3. There is a low risk of repetition.
4. The firm cooperated with the SRA's AML Proactive Supervision and Investigation teams.

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

1. Section 14B(2)(a) of Schedule 2 to the Administration of Justice Act 1985 states that we can rebuke a Recognised body where it has failed to comply with a requirement imposed by the Act or any rules applicable to the Recognised body by virtue of section 9 of the Act.
2. Taking a risk-based approach to preventing money laundering is important because it helps firms to direct resources appropriately to the highest risk areas. Firms need to understand and assess the risk posed by each client and matter, then act accordingly. 
3. For a period of seven years the firm was not meetings its responsibilities under the MLRs 2017.

5. Publication

5.1 The SRA considers it appropriate that this agreement is published in the interests of transparency in the regulatory and disciplinary process. The firm agrees to the publication of this agreement.

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

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

6.2 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.

6.3 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.

7. Costs

7.1 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.