Clayton Mott
Grafton House, 67 Loughborough Road, West Bridgford, Nottingham , NG2 7LA
Recognised body
45112

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 12 February 2026

Published date: 17 February 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

Agreed outcome

Clayton Mott (the Firm), a recognised body, agrees to the following outcome to the investigation of its conduct by the Solicitors Regulation Authority (SRA):

• it is fined £7,464
• to the publication of this agreement
• it will pay the costs of the investigation of £600.

Summary of Facts

We carried out an investigation into the firm following a desk-based review by our AML Proactive Supervision team.

Our investigation identified areas of concern in relation to the firm’s compliance with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017), the SRA Principles and the SRA Code of Conduct for Firms.

Policies, Controls and Procedures (PCPs)

Between 26 June 2017 and 1 July 2025, the firm failed to maintain compliant policies, controls, and procedures (PCPs) to mitigate and effectively manage the risks of money laundering and terrorist financing, identified in any risk assessment (FWRA), pursuant to Regulation 19(1)(a) of the MLRs 2017, and regularly review and update them pursuant to Regulation 19(1)(b) of the MLRs 2017.

Firms in scope of the MLRs 2017, must have a documented and compliant PCPs in place. 90% of the work carried out by Clayton Mott is in scope of the MLRs 2017, and in the service area of conveyancing, which has been highlighted as a high-risk area of work in the Government’s National Risk Assessments (2017 and 2020) and our Sectoral Risk Assessments (2018, 2021 and 2025) and in probate and estate administration – which are also considered areas with significant money laundering and fraud risks.

The firm’s completed AML Questionnaire stated that its PCPs were implemented on 18 July 2024 and last updated on 14 May 2025. In the same AML questionnaire, the firm stated “Prior to that there was an amalgam of policy and procedure. The assessment was recognised by the firm as outdated in its form and expert advice was sought resulting in the current document which includes proliferation financing risk assessment.”

On 5 June 2025, the firm provided a document that was previously in place, which the firm stated was an amalgamation of its FWRA and PCPs. A review of the document showed it to be SRA’s Firm-wide risk assessment template adopted by the firm (undated) and not its PCPs.

On 14 July 2025, the firm confirmed that it had misunderstood the AML Questionnaire and that its AML policy was first adopted in 2018, providing the 2018 policy and related documents (Anti-Bribery Policy, Mortgage Fraud Policy, Policy Risk document, and Money Laundering Guidance). Our review shows that the Money Laundering Guidance constitutes the firm’s PCPs under Regulation 20 of the MLRs 2007, and the Policy Risk document forms part of the AML policy by outlining its risk management and internal controls. We therefore consider that the firm did have PCPs in place under Regulation 19 of the MLRs 2017; however, the 2018 PCPs were non-compliant as they omitted key mandatory information.

On 14 July 2025, in the same email, the firm provided copies of its updated 2025 PCPs and updated FWRA. We consider both the updated FWRA and PCPs as compliant.

Admissions

The firm makes the following admissions, which we accept, that by failing to comply with the MLRs 2017:

To the extent the conduct took place before November 2019:

• Principle 6 of the SRA Principles 2011 – which states you must behave in a way that maintains the trust the public places in you and in the provision of legal services.
• Principle 8 of the SRA Principles 2011 – which states you must run your business or carry out your role in the business effectively and in accordance with proper governance and sound financial risk management principles.

And the firm has failed to achieve:

• Outcome 7.2 of the SRA Code of Conduct 2011 – which states that you have effective systems and controls in place to achieve and comply with all the Principles, rules and outcomes and other requirements of the Handbook, where applicable. 
• Outcome 7.5 of the SRA Code of Conduct 2011 – which states you comply with legislation applicable to your business, including anti-money laundering and data protection legislation.

To the extent the conduct took place from 25 November 2019 onwards:

• Principle 2 of the SRA Principles 2019 – which states you act in a way that upholds public trust and confidence in the solicitors’ profession and in legal services provided by authorised persons.
• Paragraph 2.1(a) of the SRA Code of Conduct for Firms 2019 – which states you have effective governance structures, arrangements, systems and controls in place that ensure you comply with all the SRA’s regulatory arrangements, as well as with other regulatory and legislative requirements, which apply to you.
• Paragraph 3.1 of the SRA Code of Conduct for Firms [2019] – which states that you keep up to date with and follow the law and regulation governing the way you work.

Why a fine is an appropriate outcome

The SRA’s Enforcement Strategy sets out its approach to the use of its enforcement powers where there has been a failure to meet its standards or requirements.

When considering the appropriate sanctions and controls in this matter, the SRA has taken into account the admissions made by the firm and the following mitigation:

• The firm took steps to rectify its non-compliant documents and is now compliant with the MLRs 2017.
• The firm has cooperated with the SRA’s AML Proactive Supervision and Investigations team.

The SRA considers that a fine is the appropriate outcome because:

• The conduct showed a disregard for statutory and regulatory obligations and had the potential to cause harm, by facilitating dubious transactions that could have led to money laundering (and/or terrorist financing). This could have been avoided had the firm established adequate AML documentation and controls.
• It was incumbent on the firm to meet the requirements set out in the MLRs 2017. The firm failed to do so. The public would expect a firm of solicitors to comply with its legal and regulatory obligations, to protect against these risks as a bare minimum.
• The agreed outcome is a proportionate outcome in the public interest because it creates a credible deterrent to others and the issuing of such a sanction signifies the risk to the public, and the legal sector, that arises when solicitors do not comply with anti-money laundering legislation and their professional regulatory rules.
• Rule 4.1 of the Regulatory and Disciplinary Procedure Rules states that a financial penalty may be appropriate to maintain professional standards and uphold public confidence in the solicitors' profession and in legal services provided by authorised persons. There is nothing within this Agreement which conflicts with Rule 4.1 of the Regulatory and Disciplinary Rules and on that basis, a financial penalty is appropriate.

Amount of the fine

The amount of the fine has been calculated in line with the SRA’s published guidance on its approach to setting an appropriate financial penalty (the Guidance).

Having regard to the Guidance, the SRA and the firm agree the nature of the conduct in this matter as more serious (score of three). This is because the firm should have been aware of its obligation to have in place compliant PCPs. In addition, 90% of the firm’s work falls within scope of the MLRs 2017, therefore the firm should have been familiar with the obligations imposed by the regulations and should have implemented strict adherence.

The firm has failed to meet the requirements of the regulations for a period of over eight years. Although, the firm now has compliant PCPs in place, which are in proper use, the firm was left vulnerable for a significant amount of time prior to this.

The SRA considers that the impact of the misconduct as being low (score of 2). This is because there is no evidence of any harm being caused, as a result of the firm not having compliant PCPs. The firm did have a compliant P&Ps in place under the previous MLRs 2007, which would have safeguarded the firm from criminal exploitation for that period when the MLRs 2007 were in force. However, not having compliant PCPs in place after 26 June 2017, left the firm open to money laundering abuse for a significant period. Further its 2018 PCPs failed to sufficiently detailed or adequate to comply with the regulations, which is serious when considering the majority of the firm’s work is in conveyancing.

This vulnerability is compounded by the nature of the firm’s work, which consists of 90% of its work within scope of the MLRs 2017, with a substantial proportion involving high-risk conveyancing. The lack of compliant PCPs and control measures in such a context exposed the firm to an elevated risk of being used to facilitate money laundering or terrorist financing. These deficiencies indicate that the firm’s conduct had the potential to cause a moderate impact, given the inherent risks associated with property transactions and the regulatory obligations designed to mitigate them. This suggests the firm had the potential to cause moderate impact by this conduct.

The nature and impact scores add up to five. The Guidance indicates a broad penalty bracket of between 0.4% and 1.2% of the firm’s annual domestic turnover is appropriate.

The SRA considers a basic penalty towards the top of the bracket to be appropriate which determines a basic penalty of £8,294.

The SRA considers that the basic penalty should be reduced to £7,464. This reduction reflects the mitigation at paragraph 4.2 above.

The firm does not appear to have made any financial gain or received any other benefit as a result of its conduct. Therefore, no adjustment is necessary to remove this, and the amount of the fine is £7,464.

Publication

The SRA considers it appropriate that this agreement is published in the interests of transparency in the regulatory and disciplinary process. The firm agrees to the publication of this agreement.

Acting in a way which is inconsistent with this agreement

The firm agrees that it will not deny the admissions made in this agreement or act in any way which is inconsistent with it.

If the firm denies the admissions or acts in a way which is inconsistent with this agreement, the conduct which is subject to this agreement may be considered further by the SRA. That may result in a disciplinary outcome or a referral to the Solicitors Disciplinary Tribunal on the original facts and allegations.

Acting in a way which is inconsistent with this agreement may also constitute a separate breach of principles 2 and 5 of the Principles and paragraph 3.2 of the Code of Conduct for Firms.

Costs

The firm agrees to pay the costs of the SRA's investigation in the sum of £600. Such costs are due within 28 days of a statement of costs due being issued by the SRA.