William Heath & Co And Skelly & Corsellis (William Heath & Co And Skelly & Corsellis)
16 Sale Place, Sussex Gardens, London , W2 1PX
Recognised body
050992

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 13 January 2026

Published date: 15 January 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

1. Agreed outcome

1.1 William Heath & Co and Skelly & Corsellis (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 fined £25,000
2. to the publication of this agreement
3. it will pay the costs of the investigation of £600.

2. Summary of Facts

2.1 We carried out an investigation into the firm following a desk-based review 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 and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017), the SRA Principles and the SRA Code of Conduct for Firms.

Client and Matter Risk Assessments

2.3 In all six file reviews, the firm failed to assess the level of risk, as required by Regulation 28(12) and Regulation 28(13) of the MLRs 2017.

2.4 Regulation 28(12)(a) of the MLRs 2017 states that “the ways in which a relevant person complies with the requirement to take customer due diligence measures, and the extent of the measures taken, must reflect the risk assessment carried out by the relevant person under regulation 18(1), and its assessment of the level of risk arising in any particular case.”

2.5 Regulation 28(13) of the MLRs 2017 states that in assessing the level of risk arising in a particular case, the relevant person must take account of factors including, among other things:    

2. the purpose of an account, transaction or business relationship,     
3. the level of assets to be deposited by a customer or the size of the transactions undertaken by the customer, and    
4. the regularity and duration of the business relationship.   

2.6 Regulations 28(12) and 28(13) of the MLRs 2017 therefore require firms to take steps to identify the money laundering and terrorist financing risks posed by a particular customer (or ‘client’) and matter – a client and matter risk assessment (CMRA).     

2.7 A review of the specific client files selected during the desk-based review found that none of them contained a client and matter risk assessment (CMRA).

2.8 We advised the firm that it would need to review all active files in scope of the MLRs 2017 and ensure every active matter contains a CMRA. The firm completed this review and confirmed that all matters now contain a CMRA.

Source of Funds (SoF)

2.9 In four 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.

2.10 SoF checks are vital to combatting financial crime and money laundering. understanding the source of funds (where necessary, as stipulated by Regulation 28(11)(a) of the MLRs 2017) is a fundamental part of a firm’s risk-based approach and the money laundering risk assessment of a firm’s matter. If a firm is clear around the legitimacy of a client’s source of funds, the risk of money laundering is greatly reduced. If scrutiny is not applied to a transaction, or the funds for that transaction, a firm can never truly be clear about the legitimacy of the source of funds.  

2.11 In four of the six files reviewed as part of the desk-based review, there was no evidence documented on the files to demonstrate that the firm had scrutinised the source of the client’s funds.

2.12 We advised the firm it would need to ensure fee earners are trained on completing SoF checks. We are satisfied that this has now been completed.

3. Admissions

3.1 The firm 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 November 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 fine 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 took steps to rectify the failures identified in the desk-based review
2. the firm cooperated with the SRAs AML Proactive and Investigation team.

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

1. 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. CMRAs dictate the level and extent of customer due diligence to be completed on a client or matter. Where the correct due diligence has been applied to clients and their matters, the risk of money laundering is reduced. 100% of the files reviewed were found to be in breach of the MLRs 2017.
2. Monitoring source of funds is central to the practical application of AML procedures. A failure on this aspect is a serious AML control environment failing that leaves the firm at risk of being used to launder money, and in turn increases the risk of harm. Four of six files sampled as part of the desk-based review were found not to contain insufficient checks on the source of funds being used in the transactions.
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 desk-based review determined that there was a number of control failings at the firm, demonstrating a pattern of misconduct. The firm was directly responsible for complying with money laundering legislation. It has failed to have sufficient regard to multiple warning notices and guidance published by the SRA and LSAG

5.3 In addition, the majority of the firm’s work falls within scope of the MLRs 2017, therefore the firm should have been familiar with the obligations imposed by the regulations and should have implemented strict adherence. 

5.4 The SRA considers that the impact of the misconduct was medium (score of four). This is because although there was no evidence of any direct loss to any client, the failure to appropriately risk assess clients and their matters and understand client’s SoF, for a considerable number of years, put the firm at greater risk of being used to facilitate money laundering and/or terrorist financing. 

5.5 Currently over half the firm’s business comes from conveyancing. Conveyancing is a high-risk area of work, as highlighted in our sectoral risk assessment, as property is an attractive asset for criminals because of the large amounts of money that can be laundered through a single transaction.  

5.6 The nature and impact scores add up to seven. The Guidance indicates a broad penalty bracket of between 1.6% and 3.2% of the firm’s annual domestic turnover is appropriate.

5.7 The SRA considers a basic penalty at the bottom of the bracket to be appropriate which determines a basic penalty of £28,483.

5.8 The SRA considers that the basic penalty should be reduced to £25,635. This reduction reflects the mitigation at paragraph 4.2 above.

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 to remove this.

5.10 Using our discretion for proportionality the fine has been further reduced to £25,000. This is the maximum the SRA can fine a recognised body is £25,000; anything above this must be heard by the SDT.

6. Publication

6.1 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.

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 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 2 and 5 of the 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.