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Compliance Update July 2026

Welcome to our quarter three risk and compliance update, bringing you the latest practical guidance and regulatory insights…   New rules and guidance from SRA SRA Effective Supervision Guidance – updated post-Mazur The SRA finally updated its Effective Supervision Guidance on 12 June following the Court of Appeal's decision in Mazur (expanding it from 9 pages to 24). By way of a reminder, the Court of Appeal concluded that it is lawful for an unauthorised person to carry out work amounting to the ‘conduct of litigation’ under the Legal...

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Consultation on new merger or acquisition reporting process

The SRA has announced the launch of a consultation on proposals to require law firms to notify it of prescribed events, including an advance notification of a merger or acquisition which has reached the stage of agreeing Heads of Term or similar. The SRA currently asks firms to notify it of a merger or acquisition within 28 days of the completion of the transaction. A firm which ceases to trade as a result must also notify the SRA of its closure no more than seven days in advance. As part of the SRA’s broader trend towards a more proactive...

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Amendments to the Money Laundering Regulations – how will they impact law firms?

You may recall an excitable period last summer where we were promised a “clearer and more proportionate anti-money laundering (AML) regime”, when the government recognised that AML checks were seen as a major burden to law firms?  Well, those changes, following the government’s consultation last September, are about to come into force (expected by the end of June).  Sadly, they are not as ground-breaking as perhaps some may have hoped. Indeed, the more cynical amongst us may feel they have done the opposite of the stated aim of reducing...

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AML supervision reforms – the move to the FCA – the next instalment!

We set out our thoughts on the Government’s consultation on the transfer of Anti-money laundering & counter terrorist-Financing (AML) supervision from the Solicitors Regulation Authority (SRA) (and other legal regulators) to the FCA in December last year (here). HM Treasury (HMT) has now published the response to that consultation (here). For those that had hoped the proposals may be watered down, or disappear altogether, I’m sorry to burst your bubble.  Although the resignation of our Prime Minister could have an impact on these reforms,...

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Financial Action Task Force (FATF) plenary – latest update to high risk third countries list

Following the Financial Action Task Force (FATF)’s latest plenary session, which concluded on Friday (19/6/26), the lists of high-risk countries have been updated again. As a reminder, the Money Laundering Regulations (MLRs) (still currently) require that Enhanced Due Diligence (EDD) be carried out where clients (and other parties) are established in a high-risk third country (HRTC). The UK’s HRTC list mirrors the FATF lists so it is important to be aware of any changes to the FATF black and grey lists. Although we are expecting amendments to...

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SRA Effective Supervision Guidance – updated post-Mazur…finally!

The SRA’s updated Effective supervision – Guidance was finally published on 12th June 2026.  This follows the Court of Appeal’s much-heralded ‘conduct of litigation’ judgment in the Mazur case in March (see some of our previous thoughts here).  By way of a reminder, the Court of Appeal concluded that it is lawful for an unauthorised person to carry out work amounting to the ‘conduct of litigation’ under the Legal Services Act 2007 (LSA) as long as they are doing so ‘for and on behalf of an authorised individual’ under their genuine and...

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HMRC Tax Adviser Registration – latest HMRC guidance

Further to previous posts on the subject of the new HMRC tax adviser registration requirement, HMRC has finally provided substantive guidance on who the regime applies to (see here).  The definition of a ‘tax adviser’ for the purposes of the underlying legislation (Finance Act 2026) is “an organisation or individual which, in the course of a business, assists other persons (‘clients’) with their tax affairs.”  The guidance states that ‘assistance with a client’s tax affairs’ includes (but is not limited to): advising a client in relation to...

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SRA AML & sanctions data collection exercise

A little reminder that 29th June is fast approaching – the day that the SRA’s annual AML & sanctions data collection exercise opens, with data to be provided during July. Compliance officers should be receiving (or already have received) an email from the SRA with further details (including a ‘log in’ link) about how to submit your collected data, so do look out for this (including in your junk mail into which SRA communications appear to be directed on an alarmingly regular basis!). In the meantime, here are our top tips for preparing:...

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SRA plans to protect client money

The SRA announced on 2nd June that, following their consultation on protecting client money earlier this year (see our report in our January update), they have decided to push ahead with their proposed reforms “to strengthen protections around client money”.  Although their proposals are still subject to the approval of the Legal Services Board (LSB) (which the SRA can’t take for granted given the LSB’s refusal to agree the SRA’s proposed complaints-handling rule changes in January), it is likely that we will see these in place by early next...

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SRA AML & sanctions data collection exercise – July 2026

The SRA has confirmed that its annual AML & sanctions data collection exercise will take place in July 2026, with the online portal opening on 29 June 2026. The SRA has stated that this is a regulatory requirement and firms which fail to complete the exercise may face regulatory action. The exercise is designed to help the SRA assess AML and sanctions risk across the profession and will require firms to provide information regarding: Work carried out within scope of the Money Laundering Regulations Any contact or involvement with the...

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