Regler & Company (Chinnor) Limited (Regler & Company Solicitors)
98 High Street, Thame, Oxon , OX9 3EH
Recognised body
633869

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 23 December 2025

Published date: 23 December 2025

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

1. Agreed outcome

1.1 Regler & Company (Chinnor) Limited (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 £9,500.
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.

Policies, Controls and Procedures (PCPs)

2.3 Between 26 June 2017 and 11 June 2025, the firm failed to establish and maintain any 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.

2.4 Between 12 June 2025 and 24 September 2025, the firm failed to establish and maintain 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 MLRs 2017.

2.5 On April 2025, the firm submitted a completed AML Questionnaire responding to the following question ";When was your firm's regulation 19 MLR 2017 AML policy first drafted?" The firm responded, "When the firm opened in 2011" and PCPs were updated "Every year if necessary". We note the firm started trading and received authorisation on 14 November 2016. We consider the firm was making reference to a previous law firm, namely Regler & Company which started trading on 5 July 2011 and ceased trading on 1 March 2017. The same AML questionnaire states that 45% of the firm's in scope work derives from residential conveyancing and another 25% of its work comes from commercial conveyancing. Our AML Proactive review was based on the current firm's compliance with the MLRs 2017.

2.6 As part of the desk-based review, the firm submitted a document titled 'MLR1', which we understood to be used for client due diligence. As such, it did not satisfy the requirements of a written policy under Regulation 19 of the MLRs 2017.

2.7 On 29 May 2025, we issued an outcome letter confirming the firm's failure to maintain any PCPs, alongside other deficiencies in documentation and risk controls. The outcome letter notified the firm that a referral would be made to the AML Investigations team.

2.8 On 24 September 2025, the firm provided its updated PCPs. We consider the firm's updated PCPs received on 24 September 2025, to be compliant with the MLRs 2017.

Client and Matter Risk Assessments

2.9 A review of specific client files selected during the desk-based review found that three of out of the six files did not contain a Client and Matter Risk Assessment (CMRA), as required by 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 was appropriate, as required by Regulation 28(16) of the MLRs 2017.

2.10 Two of six files did contain a CMRA; one CMRA was completed seven months after instructions were accepted, while the other was reused from a previous matter without appropriate review or update. Therefore, the firm has failed to conduct and document a matter-specific risk assessment, as required under Regulation 28(12)(a)(ii) and Regulation 28(13) of the Money Laundering Regulations 2017.

2.11 The files consisted of residential purchases putting the firm at potential risk of money laundering. The firm was utilising a form titled 'MLR2' when risk assessing client/matters. Our review of this form highlighted that it did not comply with regulations 28(12) or 28(13)(a) and of the MLR 2017. This is because the MLR2 form did not contain a risk rating or stipulate the level of due diligence that was assessed as appropriate in view of the risks presented by the client, matter or both.

2.12 On 18 June 2025, the firm provided the SRA CMRA template, stating that checklists and procedures are in place for all matters.

2.13 On 10 November 2025, the firm confirmed that in accordance with its new CMRA and firm-wide risk assessment, it was now completing a risk assessment every time a new file opened. The firm also provided evidence to demonstrate that it had now undertaken the required AML training.

2.14 Following significant engagement with the firm we now consider the firm to be compliant with the MLRs 2017 and strongly encourage it to continue to do so in all future instructions.

Source of Funds

2.15 A review of specific client files selected during the desk-based review found that four out of six client files reviewed lacked adequate Source of Funds (SoF) checks, constituting a breach of Regulation 28(11) of the Money Laundering Regulations 2017.

2.16 File A consisted of a residential purchase for £235,000. £25,000 was accepted into the firm’s client account with no evidence of the clients having these funds. Consequently, no SoF evidence was obtained.

2.17 File B consisted of a residential purchase for £315,000. £17,929.20 was received on 23 March 2023. The SoF questionnaire states that the client has £13,000 from savings and £19,000 from mortgage equity but there was no evidence obtained to show this. Consequently, there was a lack of SoF evidence.

2.18 File C consisted of a residential purchase for £580,000. Consequently, there was no SoF evidence obtained.

2.19 File D consisted of a residential purchase for £475,000. £428,000 was from mortgage advance. £30,000 as a gift. Bank statements were obtained however the bank statements did not demonstrate how the funds had become available. Consequently, there was no sufficient SoF information obtained.

2.20 Since the desk-based review, the firm has confirmed that that it has undertaken training on SoF checks and provided evidence to support this. We consider the firm to be conducting adequate SoF checks on files now and thus compliant with the MLRs 2017.

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 its failures and eventually put in place compliant PCPs and retrospectively risk assess all its client files ensuring they contain a documented CMRA and carry out adequate SoF checks. In doing so, the firm is demonstrating compliance with the MLRs 2017.
2. The firm now has a CMRA process and has completed SoF training.
3. the firm has cooperated with the SRA's AML Proactive Supervision and AML Investigations team.

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

1. The conduct showed a disregard for statutory and regulatory obligations and had the potential to cause harm, by facilitating dubious transactions that could have led to money laundering (and/or terrorist financing). This could have been avoided had the firm established adequate AML documentation and controls.
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 has failed to meet the requirements of the regulations for a period over eight years. Although, the firm now have compliant documents in place, which are in use, and is risk assessing its clients and matter, including adequately conducting SoF checks, the firm was left vulnerable for a period the SRA considers amounting to a serious breach.

5.3 The SRA considers that the impact of the misconduct was medium (score of four). This is because the firm's conduct created a significant vulnerability. The absence of any PCPs until 12 June 2025, followed by the firm's failure to maintain compliant PCPs until 24 September 2025, combined with the failure to document CMRAs and to conduct any or adequate SoF checks on four out of six files reviewed, represents a serious vulnerability and risk management.

5.4 This vulnerability is compounded by the nature of the firm's work, which consists entirely of matters within scope of the MLRs 2017, with a substantial proportion involving high-risk conveyancing. The lack of effective risk assessment and control measures in such a context exposed the firm to an elevated risk of being used to facilitate money laundering or terrorist financing. These deficiencies indicate that the firm's conduct had the potential to cause a moderate impact, given the inherent risks associated with property transactions and the regulatory obligations designed to mitigate them. This suggests the firm had the potential to cause moderate impact by this conduct.

5.5 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.

5.6 The SRA considers a basic penalty towards the top of the bracket to be appropriate which determines a basic penalty of £10,000.

5.7 The SRA considers that the basic penalty should be reduced to £9,500. This reduction reflects the mitigation at paragraph 4.2 above.

5.8 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, and the amount of the fine is £9,500.

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 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 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.