The other legal AML supervisor’s data, read the same way. Five years of the Council for Licensed Conveyancers’ annual AML reports, 2020-21 to 2024-25, every figure from the report of its own year, annotated by me.
Why read a second regulator at all? Because the FCA is due to inherit every legal AML supervisor from 2028 onwards, on the current working target, and the CLC is the clearest possible contrast with the SRA: a specialist regulator of around 200 conveyancing and probate practices, one of the National Risk Assessment’s highest-risk services, running a completely different supervisory philosophy. Put the two datasets side by side and you can see what the single supervisor is actually inheriting: not one approach, but several.
First, the denominators are tiny: 37 to 52 inspections a year, so one practice moves a percentage by two or three points. Second, mind the selection method, which changed mid-window: until the end of 2022 the CLC inspected every practice on a rolling three-year cycle, and from 2023 it moved to risk-based targeting, a change Spotlight on Corruption called the biggest shift in supervisory approach among the AML supervisors, with randomly selected low-risk practices and a guaranteed first-year visit for every new practice still in the mix. So the early years here sit closer to population rates, while the later years deliberately over-sample the practices most likely to have problems. Third, the ratings language differs from the SRA’s: the CLC’s “generally compliant” sits somewhere near the SRA’s “partially compliant”, and a single AML failure renders a whole CLC inspection non-compliant. Cross-regulator comparisons are directional, never decimal. With that said, the directions are fascinating.
Between 37 and 52 inspections and reviews a year sounds modest next to the SRA’s 966 assessments, until you divide by the population. Across the window the CLC reached about one in five of its practices each year (the CLC itself says roughly a quarter, counting its wider review tools), while the SRA’s coverage over the same five years averaged nearer one in nine. The sharper point is the convergence: by the latest reporting years the SRA has climbed to almost one in five too. The big regulator spent five years catching up to the small one’s coverage, and the CLC meets every new practice in its first year regardless of risk.
Non-compliance at inspection has never dropped below 39% in five years, and in 2024-25 not a single inspected practice earned a fully compliant rating. Before anyone writes the sector off: since the 2023 switch to targeting, this is what risk-based inspection of one of the NRA’s highest-risk services is supposed to produce, and it is no accident that the worst year on the chart, 54%, is the first full year after the switch. The CLC aims its visits at the practices most likely to have problems, finds them, and then, the genuinely distinctive part, fixes them.
Share of inspections rated non-compliant for AML, per each year’s report: 20 of 51, 18 of 40, 22 of 52, 25 of 46, 16 of 37.
Here is the five-year enforcement ledger: total fines of roughly £51,600, of which £35,000 came in a single year’s two Adjudication Panel cases. Set that against the SRA’s £2.6m in 2025-26 alone. The CLC’s model is managed compliance: a time-bound action plan, fourteen days to implement corrective actions, and the report is not signed off until everything is remedied. It works on its own terms, 20 of 22 non-compliant practices brought back in 2022-23, 15 of 16 in 2024-25, and the regulator treats the high find-rate plus the high fix-rate as the system working. But the teeth are sharpening: in April 2024 the CLC intervened into a practice, the first time it has done so in part due to AML, and referred a slate of further matters to its Adjudication Panel. The direction of travel ahead of the FCA handover is unmistakable, at both regulators.
From 226 entities to 200 in five years, and the sole practitioner is vanishing: 59 at the 2021-22 peak, 16 now. The CLC itself flags the isolated sole practitioner as an AML risk, no independent audit, no second pair of eyes, and its first AML-related intervention was a sole practice. Consolidation and supervision are pulling in the same direction.
Upper chart: total regulated entities. Lower: sole practitioners within that total.
Strip away the philosophies and the findings converge to the same short list: source of funds gathered but not scrutinised, risk assessments missing or generic, policies that describe a practice that does not exist, training that happened but nobody can prove. Five CLC reports and the SRA’s own long run of them, one failure list. Which is the strongest argument that the list is real, and the most useful fact for any firm deciding where to spend its next compliance pound, whoever its supervisor is, and whoever it is about to become.
Sources: the CLC’s Annual Anti-Money Laundering Reports for 2021, 2022, 2023, 2024 and 2025, covering the reporting years 2020-21 to 2024-25, each figure taken from the report of its own year (all published on the CLC’s website). The CLC’s own tables contain occasional percentage typos (its 2023 report shows 0.05% for 1 of 22, for example); figures here are recomputed from the underlying counts. The SRA’s equivalent view is at the five-year view and the 2025-26 page; the full analysis is in the white paper.
