AWD Legal Services Limited (AWD Law)
4 The Potteries, Wickham Road, Fareham , PO16 7ET
Recognised body
661019

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 10 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 AWD Legal Services Limited (the Firm), a recognised body, agrees to the following outcome to the investigation of its conduct by the Solicitors Regulation Authority (SRA):

1. AWD Legal Services Limited is fined £3,287 under Rule 3.1 (b) of the SRA Regulatory and Disciplinary Procedure Rules (RDPRs)
2. to the publication of this agreement under Rule 9.2 of the RDPRs
3. AWD Legal Services Limited will pay the costs of the investigation of £600, under Rule 10.1 and schedule 1 of the RDPRs.

2. Summary of Facts

2.1 We carried out an investigation into the firm following a 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 (Information on the Payer) Regulations 2017 (MLRs 2017), the SRA Principles [2019] and the SRA Code of Conduct for Firms [2019].

3. Allegation

3.1 Between 26 June 2017 and December 2022, the firm failed to have in place a documented assessment of the risks of money laundering and terrorist financing to which its business was subject (a firm-wide risk assessment (FWRA)), pursuant to Regulation 18(1) and 18(4) of the MLRs 2017.

3.2 While the firm began trading on 22 August 2019, the firm's predecessor (AWD Law LLP) was also providing a high quantity of in-scope services without the necessary FWRA. This extends the misconduct back to the start of the 2017 regulations.

4. Admissions

4.1 The firm admits, and the SRA accepts, that by failing to comply with the MLRs 2017, that it breached, for conduct up to 24 November 2019 (when the SRA Handbook 2011 was in force): 

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 provisions of legal services. 
2. Principle 8 of the SRA Principles 2011 – which states you must run in your business or carry out your role in the business effectively and in accordance with proper governance and sound financial risk management principles.

4.2 And the firm 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

4.3 And from 25 November 2019 (when the SRA Standards and Regulations came into force), the firm breached: 

5. Paragraph 2.1(a) of the SRA Code of Conduct for Firms – Which requires you to have effective governance structures, arrangements, systems and controls in place that ensure:  a- you comply with all the SRA's regulatory arrangements, as well as with other regulatory and legislative requirements, which apply to you. 
6. Paragraph 3.1 of the SRA Code of Conduct for Firms – You keep up to date with and follow the law and regulation governing the way you work.
7.   Principle 2 of the SRA Principles 2019 – Which states you must act in a way that upholds public trust and confidence in the solicitors' profession and in legal services provided by authorised persons. 

5. Why a fine is an appropriate outcome

5.1 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.

5.2 When considering the appropriate sanctions and controls in this matter, the SRA has taken into account the admissions made by AWD Legal Services Limited and the following mitigation:

1. there is no evidence of harm to consumers, or third parties, and our view is that the risk of repetition is low
2. the firm brought itself into compliance by adopting a firmwide risk assessment in December 2022
3. the firm has cooperated with the SRA's AML Proactive Supervision and AML Investigations teams.

5.3 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). The AML control failings identified as part of this investigation are necessary requirements to help mitigate against these risks.
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 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.

5.4 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.

6. Amount of the fine

6.1 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).

6.2 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 failure to have a FWRA in place before December 2022 displays firm’s negligence in understanding their obligations pursuant regulation 18 of the MLR 2017.

6.3 The firm has further demonstrated recklessness and a failure to pay sufficient regard to money laundering regulations, published guidance and SRA warning notices. Further, this forms a pattern of misconduct as the requirement has been in place since 26 June 2017, and as such, the misconduct spanned five years.

6.4 These reasons demonstrate a pattern of misconduct.

6.5 The SRA considers, and the firm agrees, that the impact of the misconduct was assessed as being low (score of two). There is no evidence of there being any direct loss to clients or actual harm caused as a result of the firm's failure to ensure it had proper AML documentation in place prior to December 2022. The other issues identified during the desk-based review were minor and have now been corrected by the firm.

6.6 The nature and impact scores add up to five. This places the penalty in Band 'B' as directed by the guidance.

6.7 The SRA and the firm agree that a basic penalty at the lower end of the bracket be appropriate.

6.8 Based on the evidence the firm has provided of its annual domestic turnover for the most recent tax year; this results in a basic penalty of £3,652.

6.9 The SRA considers that the basic penalty should be reduced to £3,287. This reduction reflects the mitigation set out in paragraph 5.2 above.

6.10 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 £3,287.

7. Publication

7.1 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. 

7.2 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. 

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

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

8.2 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. 

8.3 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.

9. Costs

9.1 The firm agrees to pay the costs of the SRA's investigation in the sum of £600.