The SRA’s AML year, in numbers

Distilled and annotated by Eloise Butterworth, FCILEX

SHOWING: THE 2024-25 REPORT · PUBLISHED 30 OCTOBER 2025

The SRA publishes its anti-money laundering annual report once a year, and most of the sector reads the headline and moves on. The detail is where the useful information lives. This page distils the 2024-25 report, the most recent published, into the numbers that should change what your firm does next, with my view on each. The 2025-26 report is due within weeks - this page will be updated the day it lands, and the badge above will tell you which year you are reading.

2024-25 on one screen

5,569

firms supervised for AML

833

firms inspected or reviewed

5,873

client files read by the SRA

13.4%

of firms checked were fully compliant

£1.5m

in fines and settlements

£148m

suspected criminal proceeds in SRA SARs

Source for every figure on this page: SRA Anti-Money Laundering Annual Report 2024-25, published 30 October 2025. Read the full report.

How compliant is the profession, really?

CompliantPartially compliantNot compliant

Overall firm compliance

112

451

270

Only 112 of 833 firms checked were fully compliant. The SRA headlines the 32% who were not compliant; the quieter number is that 87% were not fully compliant.

Firm-wide risk assessments

385

357

47% compliant, improving from 43% last year. Nineteen firms had no FWRA at all, seven years after it became mandatory, and every one was referred for investigation.

Policies, controls and procedures

311

382

130

Ten firms had no PCPs whatsoever. The most common gaps: risks of new products and practices, Companies House discrepancy reporting, and simplified due diligence.

13.4%

That is the proportion of firms checked that were fully compliant. The SRA’s own framing - “almost a third were not compliant” - is the generous reading. If your board believes your firm is in the compliant minority, the useful question is: could you prove it?

Supervision has more than tripled in five years

The full year-on-year picture, back to 2018, lives on the companion page: Five years of SRA AML supervision, charted →

Proactive AML engagements by the SRA, year by year. The direction of travel is not subtle, and whoever supervises next inherits this trajectory rather than resetting it.

And enforcement is following the same curve

AML reports received nearly doubled to 426 last year. At first glance that looks alarming. Account for the fact that the SRA now engages with more than three times as many firms as five years ago, and the headline is deceptive: relative to the amount of checking, reports have actually gone down. The total rose because the looking rose. What has genuinely risen is the consequence rate: matters ending in an enforcement outcome reached 151 including the Tribunal, roughly double the year before and triple the year before that, even allowing for the extra supervision. More looking, fewer reports per look, more outcomes per report. If you work in-house and care about risk and compliance, that last part is the one that matters.

Where firms actually fall down

The most common reasons behind the 426 reports the SRA received. Note what tops the list: not exotic typologies, but the basics, absent.

No client or matter risk assessment

162

No source of funds check

101

Inadequate or no PCPs

No firm-wide risk assessment

Inadequate firm-wide risk assessment

Failure to ID and verify the client

What 5,873 files told the SRA

16%

of files had no client and matter risk assessment, the single most common reason firms were referred for investigation

10%

of files requiring source of funds checks contained none at all

18%

of files held source of funds documents nobody had scrutinised

of files had no evidence the client was identified and verified

33%

of firms’ internal file reviews ignored source of funds entirely

Two of those numbers deserve underlining. Files held source of funds documents that nobody had scrutinised in 18% of cases: collecting is not checking. And a third of firms’ own internal file reviews ignored source of funds entirely, which is what your file reviews are quietly missing, made official.

The audit finding that should make you check yours

32%

of the independent AML audits the SRA reviewed were not compliant with Regulation 21, because they did not include file reviews. A policy review wearing an audit’s name badge, in the regulator’s own data. Less than half of firms had an audit at all, and firms with a compliant one showed higher compliance across the board. Do you actually need one? →

What non-compliance cost

£1,498,983 in financial outcomes across the year, before you count the investigations, the remediation, and the renewal conversations with insurers.

SRA adjudicator fines (15)

£292,133

Regulatory settlements (58)

£661,200

Solicitors Disciplinary Tribunal (13)

£545,650

Also in the report: the SRA itself submitted 19 suspicious activity reports covering £148m in suspected criminal proceeds, and 73% of them involved conveyancing.

The next report lands within weeks, and this page updates the day it does. If this year’s numbers made you want to check your own, that conversation costs nothing. Let’s talk.