935 SRA proactive engagements. 72% increase. All firms should expect scrutiny. Is your AML house in order?
The SRA conducted 935 proactive engagements in the year to April 2025 — a 72% increase on the previous year. The SRA's stated position is that all firms within scope of MLR 2017 should expect AML scrutiny in the near future. When the SRA visits, they review: firm-wide risk assessment, AML policies and procedures, training records, a sample of client files (checking CDD, risk assessments, source of funds), the SAR log, and the MLRO arrangements. Your agent provides a real-time compliance dashboard showing the status of every AML obligation: FWRA currency, CDD completion rates across open matters, training records, policy review dates, SAR log, and overall compliance posture. When the SRA calls, you have the evidence ready.
What Your Agent Actually Does
Your agent provides a real-time AML compliance dashboard — showing your COLP the status of every obligation and producing the evidence pack the SRA expects when they visit.
Tracks every AML obligation in one view
FWRA status, CDD completion rates, EDD triggers identified, training records, policy review dates, SAR log, MLRO arrangements — your agent tracks every MLR 2017 obligation and shows the COLP where the firm stands at a glance. Not a generic checklist but a live dashboard tied to your actual data.
Monitors CDD completion across open matters
What percentage of open matters have complete CDD? Which files are missing source of funds documentation? Where has ongoing monitoring lapsed? Your agent identifies CDD gaps across your entire caseload, not just the files the COLP happens to review.
Tracks AML training compliance
MLR 2017 Regulation 24 requires firms to take measures to ensure employees are aware of AML obligations and to provide regular training. Your agent tracks who has completed training, when, and who is overdue — producing the training records the SRA expects.
Generates SRA inspection evidence packs
When the SRA contacts you for a proactive engagement, your agent produces the evidence pack: current FWRA, policies and procedures, training records, sample CDD records, SAR log summary, and MLRO arrangements. Organised and ready, not assembled in a panic.
Produces quarterly COLP compliance reports
Your COLP needs to demonstrate systematic compliance oversight. Your agent produces quarterly reports showing AML compliance status, trends, actions taken, and areas for improvement — the governance evidence that shows the SRA your firm takes AML seriously.
The real numbers.
| Annual external AML compliance audit | £2,000–£4,000 |
| COLP time monitoring AML compliance across the firm | £1,500–£3,000/year |
| SRA enforcement risk for systemic failures | Variable (£658–£114,000+ per fine; 151 outcomes in 2024/25) |
| Realistic annual cost | £3,000–£6,000 |
| Agent build (one-off, configured to your firm and practice areas) | £2,500–£4,000 |
| Monthly running costs (hosting + AI usage) | £80–£150/month |
| SRA and MLR regulatory updates | Included in first year |
| Realistic first-year total | £3,460–£5,800 |
The SRA's 72% increase in proactive engagements is a clear signal: AML enforcement is intensifying, and all in-scope firms should expect scrutiny. For small firms where the COLP is also a fee earner, maintaining oversight of AML compliance across the entire firm is a genuine challenge.
Your agent is the compliance dashboard your COLP needs — showing exactly where the firm stands, where the gaps are, and what the SRA will find when they visit.
Good fit / not a fit.
This works brilliantly for:
- Firms within scope of MLR 2017 that haven't had an SRA engagement yet
- COLPs who want a systematic view of AML compliance across the firm
- Firms that have had SRA findings and need to demonstrate improvement
- Sole practitioners and small firms without dedicated compliance staff
This probably isn't for you if:
- You retain a specialist AML compliance consultant with ongoing monitoring
- Your firm is outside the scope of MLR 2017
- You have a dedicated compliance team with existing monitoring tools
Let's talk.
We'll start with your current AML compliance status, whether you've had an SRA proactive engagement, and what your COLP's biggest compliance concerns are. Usually a 15-minute conversation — and we'll give you a preliminary gap assessment on the call.
hello@nimblecroft.com