We’re Lexcel accredited, so our AML is covered… right?

Eloise Butterworth · 12 October 2026 · a four-minute read

This one usually arrives with a hopeful tone. The firm has worked hard for its accreditation, the certificate is on the wall, the logo is on the website, and surely all that scrutiny counts for something with the money laundering regulations too.

The straight answer: no. Lexcel and CQS are worth having and worth being proud of, but neither is an independent audit under Regulation 21, nor a prediction of how an SRA AML inspection will go. They are different instruments measuring different things, and firms get into trouble by filing them in the same drawer.

What your accreditation actually tested

Lexcel is a practice management standard. It looks at how the firm runs: client care, file management, supervision, risk management as a discipline. CQS looks at conveyancing quality specifically. Both involve an assessor, both involve evidence, and both are genuinely useful signals to clients, insurers and lenders. What neither does is test your AML framework the way the regulations require: sampling files against your own policies, interviewing the people who apply them, following the money through the client account, and evaluating whether your controls are adequate and effective in the regulation’s meaning of those words.

The level of scrutiny your AML documents receive at accreditation or re-accreditation is simply not the same exercise as an independent Regulation 21 audit or an SRA inspection. An assessor confirming your AML policy exists and looks sensible while working through reams of other policies is not an auditor doing a deep dive and testing whether anyone follows it.

Whether you need an independent audit at all turns on your firm’s size and nature. That is a decision to make and record, not assume, and your accreditation doesn’t make it for you.

Where the confusion bites

I still hear versions of “our Lexcel assessment covers our independent audit requirement”. It does not, and the moment that matters is not a quiet Tuesday, it is the SRA asking who audited your AML framework, when, what they tested and what they found. “We hold Lexcel” answers a question they did not ask. Worse, the accreditation can quietly lower the firm’s guard: the certificate becomes evidence, internally, that compliance is handled, and the specific obligations that sit outside the accreditation’s scope stop getting distinct attention.

The both/and answer

None of this is a case against accreditation. Keep it, renew it, put it in your tenders. Just file it correctly: Lexcel tells the world how your firm is run; a Regulation 21 audit tells you, and the regulator, whether your AML defences actually work. One is a badge. The other is a test. A well-run firm wants both, and knows the difference without being asked.