Rohan Solicitors LLP
Aberdeen House, South Road, Haywards Heath , RH16 4NG
Recognised body
596723

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 1 June 2026

Published date: 8 June 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

1. Agreed outcome

1.1 Rohan Solicitors LLP (the Firm), a Recognised Body, authorised and regulated by the Solicitors Regulation Authority (SRA), agrees to the following outcome to the investigation of its conduct by the 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 five of the six files reviewed did not contain a documented client and matter risk assessment (CMRA). As a result, the firm was referred for investigation.

2.2 Regulation 28(16) of the MLRs 2017 states that ‘the relevant person must be able to demonstrate to its supervisory authority that the extent of the measures it has taken to satisfy its requirements under this regulation are appropriate in view of the risks of money laundering and terrorist financing’

2.3 The firm confirmed to the SRA that, while it was assessing the risk of each client and matter, it did not begin to formally document its CMRAs until April 2025. The template CMRA provided for the DBR was compliant with Regulation 28 of the MLRs 2017, and the firm has confirmed that all active, in-scope files now contain a documented CMRA.

2.4 We therefore determined that:

Between 26 June 2017 and April 2025, the firm failed to maintain records of its risk assessment under Regulation 28 of the MLRs 2017. Therefore, the firm was unable to 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.

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 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) onwards, 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 – 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 2.2 of the SRA Code of Conduct for Firms – which states you keep and maintain records to demonstrate compliance with your obligations under the SRA's regulatory arrangements
8. 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 began to document its CMRAs in April 2025, which was prior to the DBR being carried out by the AML Proactive Supervision team. The SRA is satisfied that the firm had already taken the initiative to improve its AML control environment internally without the involvement of the SRA and is now adequately assessing client and matter risk.
2. The firm has confirmed that all active, in-scope files now contain a documented CMRA.
3. The firm has cooperated with the SRA’s AML Proactive Supervision and AML Investigations teams.

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

1. For a period of eight years, the firm was not meeting its responsibilities under the MLRs 2017.
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, and to protect against these risks as a bare minimum.
3. Some public sanction is required to uphold public confidence in the delivery of legal services. We do not consider that any less serious sanction or outcome would be appropriate to protect the public and the public interest.

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 SRA Principles and paragraph 3.2 of the SRA 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.