Chetty and Patel Limited (Chetty and Patel Limited)
133 Loughborough Road, Leicester , LE4 5LQ
Recognised body
800985

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 17 December 2025

Published date: 20 January 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

1. Agreed outcome

1.1 Chetty and Patel Limited, (the Firm), a Recognised Body authorised and regulated by the Solicitors Regulation Authority (SRA), agrees to the following outcome to the investigation:

1. a. Chetty and Patel Limited will pay a financial penalty in the sum of £15,817 under Rule 3.1(b) of the SRA Regulatory and Disciplinary Procedures Rules;
2. to the publication of this agreement, under Rule 9.2 of the SRA Regulatory and Disciplinary Procedure rules; and
3. Chetty and Patel Limited will pay the costs of the investigation of £600, under Rule 10.1 and Schedule 1 of the SRA Regulatory and Disciplinary Rules.

2. Summmary of facts

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

2.2 Our investigation 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 2019 and the SRA Code of Conduct for Firms 2019.

Firm-wide risk assessment (FWRA)

2.3 In our letter dated 4 February 2025, the firm was asked to provide its FWRA as part of the ‘pre-inspection questionnaire’. On 14 February 2025, the firm sent its AML documents and written responses to the questionnaire. The firm stated in its responses to the questionnaire that its FWRA was first drafted in June 2024.

2.4 Guidance was issued by our AML proactive team to further improve the document, and the firm sent a revised version on 19 June 2025. We are satisfied that the firm now has a compliant FWRA in place.

2.5 However, the requirement to have a FWRA has been in place since 2017 and therefore it is the case that the firm failed to take the steps necessary to comply with Regulations 18(1) and 18(4) of the MLRs 2017 from 14 August 2020 to June 2024. Policies, controls and procedures (PCPs)

2.6 In our letter dated 4 February 2025, the firm was asked to provide its PCPs as part of the ‘pre-inspection questionnaire’. On 14 February 2025, the firm sent its AML documents and written responses to the questionnaire. The firm stated in its responses to the questionnaire that its PCPs were first drafted in June 2024.

2.7 Further, the PCPs the firm sent to the SRA were missing the following sections mandated by Regulation 19:

• Mitigation of Money Laundering/Terrorist Financing risk involving new products, practices or technologies - regulation 19(4)(c)
• Customer Due Diligence (CDD) – Identification and verification measures – regulation 28
• The taking of additional measures, where appropriate, to prevent the use for money laundering or terrorist financing of products and transactions which might favour anonymity – regulation 19(4)(b)
• Checking the sanctions register/complying with the sanctions regime – regulation 33
• Reporting discrepancies to Companies House – regulation 30A

2.8 The firm was provided with guidance on bringing its PCPs into compliance and on 19 June 2025, the firm sent in its revised PCPs. Upon review, it was clear that the guidance provided was considered and we are satisfied that the firm has compliant PCPs in place.

2.9 Therefore, it is the case that between 14 August 2020 and June 2024, the firm failed to establish and maintain 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.

2.10 Further, as the firms PCPs were non-compliant at the time of the DBR, it is also the case that between July 2024 and 19 June 2025, the firm failed to establish and maintain fully 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.

Client and matter risk assements (CMRAs) / customer due diligence measures

2.11 In our letter dated 4 February 2025, the firm was asked to provide its ‘template client and matter risk assessment’. The firm was able to provide a template CMRA, however as part of the inspection, six client files were reviewed and three of these files did not contain a CMRA, or any form of risk assessment. There was no document on these three files to indicate the risk of client or matter had been considered and understood at instruction. Consequently, there was no documentation confirming the level of customer due diligence applicable to each file. It was therefore apparent that the CMRA was not in proper use at the time of the DBR.

2.12 On 19 June 2025, the firm sent the Investigation Officer a revised CMRA form and confirmed that all appropriate staff had been trained on completing this new form. This updated CMRA form was reviewed, and we are now satisfied that the firm are adequately risk assessing client and matter in accordance with Regulations 28(12) and 28(13) of the MLRs 2017.

2.13 Therefore, it is the case that on three out of six files reviewed, the firm failed to assess the level of risk, as required by Regulation 28(12) and Regulation 28(13) of the MLRs 2017.

SOF

2.14 As part of the DBR, six files were reviewed. Three out of six of these files did not have any evidence or documentation to demonstrate the appropriate SoF information had been obtained.

2.15 All three files reviewed were property purchases. Conveyancing is considered a high-risk area and therefore all files should have contained adequate documentation to show the origin of funds used in the transaction and should be able to demonstrate that these documents have been properly scrutinized.

2.16 Therefore, it the SRA’s case that on three out of six files reviewed, the firm failed to carry out adequate source of funds checks, in accordance with Regulation 28(11)(a) of the MLRs 2017.

3. Admissions

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

1. 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.
2. 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.
3. 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.

4. Why a fine is an appropriate outcome

4.1 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.

4.2 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.

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

1. 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.
2. There has been no evidence of harm to consumers or third parties and there is now a low risk of repetition.
3. The firm has assisted the SRA throughout the investigation and has shown remorse for its actions.
4. The firm did not financially benefit from the misconduct.

4.4 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.

5. Amount of the fine

5.1 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).

5.2 Having regard to the Guidance, we and the firm agree that the nature of the misconduct was more serious (score of three). This is because the firm should have been aware of its obligation to have in place a FWRA and PCPs since it began trading. Further, the firm had obligations to be carrying out a CMRA and relevant SoF checks on all in-scope files. In addition, a significant proportion 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.

5.3 The firm has failed to meet the requirements of the regulations over many years, while carrying a large proportion of work that falls within scope of the regulations. Although the firm now has compliant documents in place, which are in proper use, the firm was left vulnerable for a significant period of time, and the SRA considers that this amounts to a serious breach.

5.4 The impact of the harm or risk of harm is assessed as being medium (score of four). This is because although there is no evidence of any harm being caused, as a result of the firm not having compliant AML documents in place, the nature of its work, in particular its significant percentage of in-scope work, suggests the firm had the potential to cause moderate impact by this conduct.

5.5 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% to 3.2% of the firm’s annual domestic turnover.

5.6 We recommend a basic penalty towards the top of the bracket. This is because the firm should have been aware of its statutory obligations under the MLRs 2017. The firm’s breaches were serious, as the firm lacked the core mandatory AML documentation required both at firm level (FWRA/PCPs) and at file level (CMRAs/SoF). However, the firm has now brought itself into compliance and therefore the ongoing risk is low.

5.7 Based on the evidence the firm has provided of its annual domestic turnover this results in a basic penalty of £18,608.

5.8 We have also considered mitigating factors and consider that the basic penalty should be discounted by fifteen percent. This is to take account of the following factors as indicated by the Guidance:

1. (a) Remedy harm – the firm took steps to rectify its breaches and is now fully compliant with the MLRs 2017.

Cooperating with the investigation – the firm has cooperated with the SRA’s AML Proactive and AML Investigation teams.

5.9 The adjusted penalty is therefore £15,817.

5.10 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 £15,817.

6. Publication

6.1 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.

6.2 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.

7. Acting in a way which is inconsistent with this agreement

7.1 The firm agrees that it will not act in any way which is inconsistent with this agreement, such as by denying responsibility for the conduct referred to above. This may result in a further disciplinary sanction.

7.2 Acting in a way which is inconsistent with this agreement may also constitute a separate breach of Principles 1, 2 and 5 of the SRA Principles.

8. Costs

8.1 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.