Compl:ex Articles

Compl:ex Issue 8

Residual Balances: The Compliance Time Bomb in Your Client Account

As a regulatory and disciplinary solicitor working exclusively with solicitors and law firms, my engagement is rarely with practices that are fully compliant. Instead, I encounter firms and individuals under investigation by the SRA or facing internal sanctions or referral to the Solicitors Disciplinary Tribunal (SDT).

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Client Money Under Scrutiny: SRA Breaks its Silence

On 21 September, the SRA released its long-awaited update following the consultation Client Money in Legal Services – Safeguarding Consumers and Providing Redress, some seven months after the consultation closed. The exercise attracted more than 450 responses, incorporating event feedback, consumer research and wide-ranging industry commentary.

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High Alert: What the SRA’s 2025 AML Risk Assessment Means for Conveyancing Firms

Money laundering remains one of the most significant threats to the legal profession and enforcement activity in this area remains high. The SRA’s Sectoral Risk Assessment acts as a roadmap for the regulator’s expectations. Published on 31 July 2025 this is essential reading for every conveyancing firm.

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Verification, Transparency and Change: What Law Firms Need to Know About the Companies House Reforms

The Economic Crime and Corporate Transparency Act 2023 (ECCT Act) is reshaping the UK’s corporate landscape. It represents the most significant overhaul of the company registration regime since 1844, when Companies House was first established. The reforms mark a decisive shift towards greater transparency, accountability and the prevention of economic crime.

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It is abstract, darling.

The term ‘mambypambyism’ was coined by Henry Carey in 1725 to mock sentimental excess, and I have a simple yet ruthless suggestion for running Government.

If the NHS adds one million people to the waiting list, the minister should resign immediately, the same for economic regression, the Chancellor should go in haste with no long goodbyes, and the apologies should rain down upon us along with the P45 of the Prime Minister. A revolving door installed on every ministerial building sounds just the ticket, regardless of the political stripes in power; it is simple and should provide a raw attention to detail and sharpen a few pencils well before General Elections are called for.

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Compl:ex Issue 7

Internal Audit: A Strategic Advantage for Forward-Thinking Law Firms

When you hear the phrase “internal audit,” the picture you naturally jump to is one of a box-ticking, clipboard based, reactive exercise perhaps only relevant to large corporations.  30 years ago, you would have been correct with this assumption. 

However, Internal Audit has come a long way with successful, forward thinking and growing law firms utilising Internal Audit as a dynamic, strategic function that drives value creation, improves governance and helps Executive Boards achieve their long-term goals. Far from being an administrative overhead, it offers valuable insights into operational resilience, risk management and governance unlocking real competitive advantage in an increasingly complex legal landscape.

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Phishing Is Getting Smarter and It’s Targeting Law Firms

Phishing might once have seemed like a distant or obvious threat, but in 2024/25, it has become more sophisticated, more personal and a far greater threat to law firms.

Phishing is the act of tricking individuals into revealing sensitive information such as passwords, payment details, or login credentials by posing as a trustworthy source. It often comes in the form of emails, texts or even phone calls that appear genuine but are designed to deceive.

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M&A in the Legal Sector: Opportunity, Risk and Regulatory Reality

The legal sector has entered a new phase in the mergers and acquisitions (M&A) cycle, one marked by scale, ambition and scrutiny, with publicly listed firms like Knights making headline-grabbing acquisitions.

The ink was not dry on the print following the announcement of the £30M acquisition of IBB Law before the £16.6M deal for Birkett Long was made public. This is a time of opportunity for the sector, but also one of real compliance complexity and risk

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The New Failure to Prevent Fraud Offence: What it Means for Law Firms

The new “failure to prevent fraud” offence, introduced under the Economic Crime and Corporate Transparency Act takes effect from September 2025, and law firms can’t afford to ignore it.

On the surface, it’s a corporate offence aimed at tackling fraud but beneath that, it’s a cultural shift, a legal requirement to take fraud that may benefit the organisation risk seriously.

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Legal Aid Agency Cyber Breach Forces Law Firms to Reassess Client Risk and Compliance

The recent cyber breach at the Legal Aid Agency (LAA) has sent ripples across the legal sector, with potentially far-reaching consequences for firms connected to the Legal Aid Agency system. While the breach did not directly target individual law firms, the exposure of highly sensitive client data including National Insurance numbers, dates of birth, and other personal identifiers has placed a significant compliance burden on those who rely on LAA systems or work with legally aided clients.

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New Data Protection Laws – Together in Digital Dreams

The Data (Use and Access) Act 2025 (DUAA) has now received Royal Assent; data is the new oil.
The Government has announced that in this multi-connected digital age, consumers will benefit from streamlined services in the NHS and GP appointments. How smart data will boost the labour market, give a much-needed £10 billion leg-up for the economy, and so much more. Hurrah!

The problem with anything that makes consumers’ lives easier is the detail of the legislation; the meaningful advancements are easy sells, but what about the terms, the small print and the impact on businesses?

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Compl:ex Issue 6

Axiom Ince Scandal: Serious Fraud Office charges five men over missing millions

The legal profession relies on trust—trust between lawyers and clients, trust in regulatory oversight, and trust in the ethical obligations that underpin our system of justice. The recent charges brought by the Serious Fraud Office (SFO) against five individuals connected to the now-defunct law firm Axiom Ince…

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Revolutionising Digital Identity: The Impact of the Smart Data Bill

Over the last few months, there have been several significant developments in the field of digital identity verification, primarily driven by the government’s new Data (Use and Access) Bill.

Commonly referred to as the Smart Data Bill, this legislation is central to the government’s plan to modernise the economy, covering aspects from digital ID verification to new smart data schemes and data protection reforms

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AML Training for Law Firms: The SRA’s Thematic Review and What It Means for You

The Solicitors Regulation Authority (SRA) has published a thematic review on AML training requirements for law firms. This has resulted in a highly practical and useful checklist for firms to use and implement, highlighting the critical role of staff training in preventing money laundering and protecting firms from regulatory and criminal risks. The findings emphasise that while most firms acknowledge the importance of AML training, many fall short in implementation, record-keeping, and engagement.

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Sham Litigation: New SRA Guidance

The Solicitors Regulation Authority (SRA) issued new guidance on sham litigation in January. Sham litigation is an often-overlooked risk that could expose law firms to money laundering, fraud, and reputational damage. Law firm leaders must stay vigilant, recognise red flags, and implement safeguards to prevent criminal exploitation of legal processes…

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Why your Sofa is Killing you, softly - Last Words

Why your sofa is killing you, softly.

Until the end of December 2024, Labour created a quango weekly, ordering more than 60 reviews and consultations. It’s a dramatic big-bang theory for unlocking growth. Get the industry captains in alongside the learned emeritus and pump them for information, create dramatic short sprints of tasks, and see what new thinking spills out…

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Compl:ex Issue 5

Risky Business – How to Ensure your Post Completion Work doesn’t Fall Foul of the CLC

Julie Sorby highlights the CLC’s 2024 Risk Agenda’s concerns about post-completion work in conveyancing, emphasising the importance of diligence and integrity. Discover how ICOS, X-Press Legal Services’ Intelligent Conveyancing Online System, streamlines post-completion processes, reduces errors, and ensures compliance, ultimately supporting conveyancers and benefiting clients.

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Need to Know, SRAs Compliance Officers Conference 2024

Need to Know: SRA’s Compliance Officers Conference 2024

Kate Burt highlights the significance of the SRA’s Compliance Officers Conference on 5 November 2024, focusing on vital topics such as AML, cybercrime, and legal technology. Whether attending in-person or virtually, learn why this annual event is crucial for compliance professionals to stay updated on regulatory changes and network with industry leaders. Reserve your spot today!

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The Risks of Social Engineering

Social Engineering: A Legal Perspective

Explore the growing threat of social engineering tactics, including phishing and pretexting, that exploit human psychology. This article outlines common techniques, real-world case studies, and essential strategies for legal professionals to safeguard their practices and protect client information from potential breaches.

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A warning from the Regulator on Law Firm Mergers and Acquisitions

A Warning from the Regulator on Law Firm Mergers and Acquisitions: Compliance and Best Practices for Conveyancing Firms

Kate Burt discusses the SRA’s Warning Notice on mergers and acquisitions in the legal sector, focusing on the critical compliance risks for conveyancing firms. Discover best practices for safeguarding client interests, conducting thorough due diligence, and ensuring effective governance to successfully navigate M&A transactions while maintaining client trust.

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Riddles in the Dark and Labours Housing Policy - Christian Lister, Complex Issue 5

Riddles in the Dark and Labour’s Housing Policy

Christian Lister explores the complexities of land ownership in the UK, where 12% is held by various entities, including the Forestry Commission and the National Trust. Delve into the political implications of housing developments, conveyancing intricacies, and the potential for litigation involving local authorities and private interests.

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Compl:ex Issue 4

What is Open Banking? 

Open Banking is a type of secure guided bank transfer. It’s quicker and cheaper than clients paying by card or PayPal, and more secure and less prone to mistake and fraud than a bank transfer, cheque or CHAPS. 

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Would your internal procedures have uncovered this fraud? 

Last month a law firm employee was convicted and sentenced to four years in prison after siphoning charity donations over a 13-year period. Effected beneficiaries included Cancer Research, Great Ormond Street and local hospices along with various animal charities.

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The Curious Case of Unconventional Money Transfers

Property transactions are synonymous with money transfers however the UK property market has witnessed some peculiar alternatives to cash that have been used to secure a property. 

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The death knell tolls for trust in solicitors as removal of client account is mooted?

Paul Philip, chief executive of the Solicitors Regulation Authority (SRA) caused much debate last month when he announced that the cost of regulation would ‘drop like a stone’ if solicitors were not allowed to hold client money. This coincided with news that, increasingly, some law firms are turning to third party managed accounts (TPMA) providers to handle their client money, thus reducing or, in some cases, negating the need for accounts staff in law firms entirely. 

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Embracing AI in Law: The Delicate Dance of Innovation and Compliance

Recently, I participated in the SRA’s Innovation: Technology and AI event where Microsoft showcased its ‘legal document drafting’ application and highlighted the benefits of retraining employees to integrate this new technology using meta prompts

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Compl:ex Issue 3

Increased capacity surge increases competition

As the April 1st renewal deadline looms closer, many law firms in the UK are feeling the pressure of their professional indemnity insurance (PII) renewal process.

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Why collaboration is key to compliance

Property fall throughs are estimated to have cost UK buyers and sellers £270m during Q3 of 2023 with a staggering 269,728 of property sales falling through during the course of the year.

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Navigating Crypto Due Diligence in Conveyancing

As the landscape of finance continues to evolve, the emergence of cryptocurrencies has brought about both excitement and apprehension among professionals in the legal sector, particularly those involved in conveyancing.

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Lessons from Clyde & Co’s £500,000 Fine

By now most firms are aware of the well-publicised SDT decision in which Clyde & Co was fined a staggering £500,000 for AML failings. 

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Not all heroes wear capes

A letter arrives from SRA the notifying you of their intention to review your firm. The SRA is available to attend for a visit in a fortnight, a month or six months’ time….

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Compl:ex Issue 2

Top 10 Tips for Avoiding a Professional Negligence Claim

Karim Mohamed, Partner in Professional Negligence at Lime Solicitors in Sheffield, has thirty years’ experience helping clients with negligence claims against all kinds of professionals. Here Karim shares with Complex readers his top ten tips for solicitors to protect against professional negligence claims.

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AI: friend or foe?

A poll of 700 companies by the British Chambers of Commerce in September found that just under half had no plans to use AI, a figure that rose to 58 per cent for businesses selling to consumers. This is despite reports that in August 180.5 million people worldwide were using ChatGPT, one of the leading generative AI chatbots that have emerged this year.

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Should we charge for Due Diligence?

This is an area which is often misunderstood by firms and whilst many firms are now confident to factor onboarding into their pricing, there are many firms that simply don’t realise that this is an option.

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AML Audit… a visit from the SRA

The SRA is coming to visit and as the firm’s MLRO it’s the one thing you’ve been preparing for your entire career! You’re really looking forward to showcasing the processes and procedures you’ve diligently perfected over the years and how they are working so well. Files are pristine and personnel know your procedures verbatim. All that’s now needed is to decide what biscuits to offer on the day!

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The era of open banking has arrived 

At The Law Society’s National Conference in October, Peter Rodd, chief assessor for the Conveyancing Quality Scheme, told the 11% of firms who said they have not undergone a recent audit of practice-wide risk assessment for anti-money laundering, to get an audit done. 

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Compl:ex Newsflash

Compl:ex Newsflash, the latest news and guidance; Don’t let your November start with an SRA fine & Professional Indemnity Insurance Renewals.

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Compl:ex Issue 1

AML anxiety? You’re right to be worried

We couldn’t launch our inaugural issue of Compl:ex without including mention of AML checks.  They are the beginning of every property transaction and in many ways were also catalyst for the creation of Compl:ex.

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Navigating challenges relating to funds from China

The National Crime Agency has described Chinese underground banking as ‘the most prevalent money laundering threat faced across the Western world’.

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A word on whistleblowing

Whistleblowing – we all know what it is but how much time are we dedicating to it?

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Is this overkill? Sanctions checks on clients and counter parties

It’s no secret that the SRA is taking an active interest in how firms are approaching their management of the sanctions regime.

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Cyber Essentials podcast

Scott Reece, Head of IT Services at X-Press Legal Services takes a deep dive into Cyber Essentials with Geoff Coote CEO of Pro Networks Ltd.

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