Minahan Hirst & Co Limited (Minahan Hirst & Co )
33 Station Road, Cheadle Hulme, Cheadle , SK8 5AF
Recognised body
522149

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 13 April 2026

Published date: 23 April 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

Minahan Hirst & Co Limited T/A Minahan Hirst & Co (the Firm), a Recognised Body, authorised and regulated by the Solicitors Regulation Authority (SRA), agrees to the following outcome to the investigation:

• it will pay a financial penalty in the sum of £12,774, under Rule 3.1(b) of the SRA Regulatory and Disciplinary Procedure Rules;
• to the publication of this agreement, under Rule 9.2 of the SRA Regulatory and Disciplinary Procedure Rules; and
• it will pay the costs of the investigation of £600, under Rule 10.1 and Schedule 1 of the SRA Regulatory and Disciplinary Procedure Rules.

Summary of Facts

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

Our inspection identified areas of concern in relation to the firm's compliance with the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017 (MLRs 2017), the SRA Principles 2011, the SRA Code of Conduct 2011, the SRA Principles [2019], and the SRA Code of Conduct for Firms [2019].

Policies, Controls and Procedures (PCPs)

The firm's AML PCPs were repeatedly found to be deficient between 2017 and January 2026, despite assurances of updates. Reviews identified that earlier PCPs were incomplete and non compliant with Regulation 19 of the MLRs 2017, with the firm at one point submitting a Firm- Wide Risk Assessment in place of PCPs. Compliant PCPs were finally provided in January 2026

Source of funds (SoF)

We identified that, prior to the DBR, the firm had inadequate AML arrangements on live files, including inadequate SoF checks on file, resulting in non compliance with the MLRs 2017 until remedial action was taken.

Allegations

Between 26 June 2017 and 31 January 2026, 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.

A review of specific client files selected during the DBR found that two out of six client files reviewed lacked adequate Source of Funds (SoF) checks, constituting a breach of Regulation 28(11) of the Money Laundering Regulations 2017.

Admissions

The firm admits, and the SRA accepts, that by failing to comply with the MLRs 2017 that it breached:

To the extent the conduct took place before 24 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 provisions 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 failed to achieve:

• Outcome 7.2 of the SRA Code of Conduct 2011 – which states 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 mater, the SRA has taken into account the admissions made by the firm and the following mitigation:

• There has been no evidence of harm to consumers or third parties and there is a low risk of repetition.
• The firm has assisted the SRA throughout the investigation and has shown remorse for its actions.
• The firm did not financially benefit from the misconduct.

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 conducted sufficient, or any, source of fund checks on six of the eight files reviewed.
• 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, we, and the firm agree that the nature of the misconduct in this matter is more serious. This is because the firm was directly responsible for complying with the Money Laundering Regulations in place at the material time. The firm failed to maintain compliant PCPs between 26 June 2017 and 31 January 2026.

This is a serious breach as the firm remained non-compliant for a period of over eight years. At file level, our review identified systemic deficiencies. Specifically, that despite an inherent risk on conveyancing, the fee earner failed to conduct any, or adequate, SoF checks on two of the six files, in relation to property transactions, one of the transactions was a cash purchase.

These checks are critical safeguards under the MLRs, particularly in conveyancing, which is widely recognised as a high-risk sector for money laundering. These practices fell well below the expected standard and undermine the purpose of risk-based assessments.

The firm's approach demonstrates a serious disregard for its regulatory obligations and a cavalier attitude towards mitigating money laundering risk. Such failures not only breach the MLRs but also create an inadvertent and unacceptable risk of facilitating criminal activity in the legal profession and exposing the UK economy to it.

The firm has failed to meet the requirements of the regulations for a period of over eight years, since the MLRs 2017 came into force. Although, the firm now have compliant documents in place, which are in use, and is adequately conducting SoF checks, the firm was left vulnerable for a period the SRA considers amounting to a serious breach.

The impact of harm or risk of harm score is assessed as being medium (score of four). This is because although there is no evidence of actual harm (and even if there was actual harm, we have not been privy to this information).

Having non-compliant PCPs until 31 January 2026, expands over a period of eight years and its failure to conduct any or adequate SoF checks on two out of six files reviewed, represents a serious vulnerability. It is because of the SRA's intervention, that the firm has become compliant with its obligations under the MLRs.

This vulnerability is compounded by the nature of the firm's work, which consists entirely of matters within scope of the MLRs 2017, with a substantial proportion involving high-risk conveyancing.

The lack of effective risk assessment 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.

The 'nature' of the conduct and the 'impact of harm or risk of harm' added together give a score of seven. This places the penalty in Band “C,” as directed by the Guidance, which indicates a broad penalty bracket of between 1.6% and 3.2% of the firm's annual domestic turnover.

Based on the evidence the firm has provided of its annual domestic turnover; this results in a basic penalty of £14,193.

The SRA considers that the basic penalty should be reduced to £12,774. This reflects the firm's transparency and cooperation with the AML Proactive Supervision team and AML Investigations team, along with admitting and remedying the breaches.

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, and the financial penalty is £12,774.

Publication

Rule 9.2 of the SRA Regulatory and Disciplinary Procedure Rules states that any decision under Rule 3.1 or 3.2, including a Financial Penalty, shall be published unless the particular circumstances outweigh the public interest in publication.

The SRA considers it appropriate that this agreement is published as there are no circumstances that outweigh the public interest in publication, and it is in the interest of transparency in the regulatory and disciplinary process.

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.