In 2023, a solicitor was convicted for the first time ever for tipping off, alerting a client that they were under investigation for money laundering. It was a landmark moment.
Here is what tipping off means in practice, where the line is, and how to stay well clear of it.
Why has tipping off become a focus for law firms?
For years, tipping off appeared in AML training as a theoretical risk. Solicitors understood it was an offence, but many assumed enforcement actions were rare or confined to other sectors.
The 2023 conviction changed that perception. A solicitor was found guilty under section 333A of the Proceeds of Crime Act 2002, marking the first time a member of the legal profession had been convicted of this specific offence. The case sent a clear signal that the legal sector is within scope for enforcement and that regulators are taking a more active interest.
Understanding what tipping off means in practice, and where the risks arise in day-to-day work, is now an essential part of AML compliance.
What is tipping off under UK AML law?
Tipping off occurs when someone who knows or suspects that a Suspicious Activity Report has been made discloses information to another person in a way that is likely to prejudice any resulting investigation.
In practical terms, if a report has been submitted or is suspected to have been submitted, the firm must not inform the client. This includes avoiding any statements or behaviour that could suggest they are under scrutiny.
The offence applies across the regulated sector, including legal professionals, and carries a maximum penalty of two years’ imprisonment and an unlimited fine.
Where is the line between communication and tipping off?
Two conditions must be met for the offence to arise. The person making the disclosure must know or suspect that a report has been made, and the disclosure must be likely to prejudice an investigation.
In practice, the definition of what may prejudice an investigation is broad. Referring to delays as being due to “compliance reasons”, providing vague or evasive explanations, or indicating that a matter has been escalated internally may create risk depending on the context.
The safest approach is to avoid any reference to the existence of a report. Where a transaction is delayed, a neutral explanation such as the need to complete standard checks or allow more time is generally acceptable, provided it does not imply that a report has been made.
What is the SAR moratorium period and why does it matter?
Where a Suspicious Activity Report is submitted requesting consent to proceed with a transaction, the firm must wait for a response from the National Crime Agency.
The initial period is seven working days. If no refusal is received within that time, consent is deemed to have been granted. If consent is refused, a further 31-day moratorium period applies during which the transaction cannot proceed.
During this time, the client cannot be told why the matter is delayed. This creates a practical challenge, as clients may expect progress and seek explanations. Firms that manage this risk effectively tend to prepare standard responses in advance rather than relying on ad hoc explanations.
What related offences should firms be aware of?
Section 342 of the Proceeds of Crime Act 2002 creates a separate offence of prejudicing an investigation. Unlike tipping off, this does not require a report to have been made. If someone knows or suspects that an investigation is underway and takes steps that could interfere with it, the offence may apply.
This reinforces the need for caution at an early stage. The risk does not begin only once a report is submitted, but from the point at which suspicion arises.
How should firms manage tipping off risk in practice?
Managing tipping off risk requires preparation rather than improvisation. All staff involved in client work should understand what tipping off is and why careful communication matters.
The Money Laundering Reporting Officer should be involved as soon as a report is being considered, so that communication with the client can be managed consistently. Firms should also develop agreed language for responding to delays or questions, ensuring that fee-earners are not required to decide how to respond in real time.
It is also important to recognise that internal reporting to the MLRO is not tipping off. It is a separate legal obligation and a critical part of the firm’s AML framework.
Tipping off is best understood as a risk that arises from how information is communicated, rather than from the act of reporting itself. Once suspicion exists, even well-intentioned explanations can create exposure if they suggest what is happening behind the scenes. The legal threshold is broad, and the consequences are significant.
Firms that manage this effectively do so by putting clear processes, training, and agreed client communication in place so that responses are measured, consistent, and do not depend on judgement in the moment.
Risk assessments are the foundation of AML compliance and, according to the SRA, the area where law firms most commonly get it wrong.
Here’s what a good one actually looks like, and why the tick-box approach keeps getting firms into trouble. All of that, in a five minute blog.
Why Risk Assessments Keep Coming Up
Every year, the SRA publishes its findings from AML supervisory visits across the legal sector. And every year, risk assessments sit at the top of the failure list.
In the most recent reporting period, the SRA carried out 935 proactive AML engagements across 833 firms. Around one in three were found to be non-compliant. The most common reasons were gaps in firm-wide and client risk assessments, weaknesses in AML controls, and limited internal monitoring. Risk assessments appear in almost every category of failure.
This isn’t a new problem, but the SRA’s tone has sharpened. Firms are increasingly expected to demonstrate that their risk assessments are active, documented, and driving real decisions, not sitting in a folder as evidence of compliance.
Two Separate Assessments, Two Separate Obligations
There’s a distinction worth being clear on, because conflating the two is itself a common failure.
The firm-wide risk assessment is required under Regulation 18 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. It must be a written document, approved by senior management, that identifies the money laundering and terrorist financing risks the practice is exposed to, based on its client base, geographic exposure, services offered, and transaction types. It should be reviewed regularly and updated when the firm’s circumstances change.
The client and matter risk assessment is required under Regulations 28(12) and (13) and must be completed for every single instruction. It needs to reflect both the specific characteristics of that matter, including the client, the transaction, the source of funds, and any risk indicators, and the broader context set by the firm-wide assessment. One informs the other.
The SRA has been clear that the firm-wide assessment is not a substitute for individual matter-level assessments. Both are required. Both must be documented.
What the SRA Keeps Finding
Across its 2024–25 supervisory activity, the most persistent risk assessment failures cluster around a few consistent themes.
Assessments are not always completed consistently or in full. Client and matter risk assessments are sometimes skipped entirely, partially completed, or completed after the matter has already progressed, which defeats the purpose.
Tick-box approaches are still common. Forms are filled in, but the answers do not reflect genuine consideration of the matter. Risk ratings are applied without reasoning, despite the SRA making clear it expects to see evidence that the assessment informed a decision, not just that it was done.
Firm-wide risks are not always carried through to client level. If a firm’s firm-wide assessment identifies elevated risk areas, that should be visible in how individual matters are assessed. Where there is no connection between the two, it is a clear red flag.
High-risk matters do not always receive appropriate oversight. Situations involving PEPs, complex ownership structures, or source of funds concerns should trigger escalation, but the SRA has found cases where this has not happened.
Assessments are often completed once and never revisited. Risk does not stop at onboarding, and where circumstances change, the assessment should change with them.
What a Good Risk Assessment Actually Looks Like
The SRA’s guidance, along with practical experience across the sector, points to a consistent set of characteristics.
Effective risk assessments are completed before the matter progresses, not retrospectively. They contain clear reasoning rather than just a risk rating, explaining what factors were considered and what that means in practice.
They are connected to the firm-wide picture, reflecting the risks identified at firm level in individual matters. They are also treated as live documents, revisited when circumstances change rather than filed away and forgotten.
Finally, they create a clear audit trail. It should be obvious when the assessment was completed, who carried it out, and what actions followed as a result.
The Difference Technology Makes
Manual risk assessments inevitably introduce inconsistency. Some fee-earners apply them rigorously, others less so. Digital AML workflows help address this by embedding risk assessment into the process itself.
They can make completion mandatory at the point of matter creation, prompt the right questions based on the specific context, automatically flag higher-risk scenarios, and create a clear, auditable record of decisions made.
This does not replace professional judgement. It supports it, ensuring that risk assessment is applied consistently and at the right time, rather than retrospectively or unevenly.
Taken together, the SRA’s message is consistent. Firms need both a firm-wide risk assessment and a matter-level assessment for every instruction, and both must be properly documented, actively used, and kept up to date. Completing them after the fact, or treating them as a formality, misses the point entirely. The real test is whether the assessment has shaped how the matter is handled, particularly where higher-risk scenarios require escalation or further scrutiny.
There’s a particular kind of stress that comes with being responsible for something you can’t control.
You’ve done the work. You’ve filed everything correctly. But the transaction is slow, the client is anxious, and every time your phone rings you already know why. You handle it. You move on. You do the same thing on the next file.
That accumulates. And because it’s so consistent, because it’s just how the job is, it’s easy to stop noticing.
It’s worth naming what that actually is. You’re being asked to absorb anxiety you didn’t create, on a timeline you can’t influence, while remaining the calm, professional point of contact for everyone involved. That’s not just difficult, it’s a specific kind of difficult. The kind that doesn’t always get acknowledged because it looks, from the outside, like you’re just doing your job.
Mental Health Awareness Week feels like a reasonable moment to say: yes, but at what cost.
The things that genuinely help
None of these will be news to you. But they’re worth saying plainly.
- Set boundaries where you can: You don’t have to be reachable by every client at all hours. Most clients, given clear expectations early in the relationship, will work within them. The ones who won’t are a different problem, but they’re the exception, not the rule.
- Get your caseload visible: The ambient pressure of not quite knowing where everything stands is draining in a way that’s easy to underestimate. A clear picture of what’s actually in progress, even a basic one – reduces that background noise.
- Talk to someone: Conveyancing can be oddly solitary for a team-based job. If something is weighing on you, speak to a colleague, a supervisor, or someone outside work. It helps more than you realise.
- Know that support exists: LawCare provides free, confidential help to anyone working in the legal sector. It’s not just for crisis situations. lawcare.org.uk
The connection between the two
Everything in the guide we published this week applies to you as much as to your clients. Every proactive update you send is one fewer anxious call to deal with. Every clear expectation you set is one fewer difficult conversation. The habits that reduce client anxiety also, quietly, reduce yours.
That’s not a coincidence. It’s the point.
The full guide: Managing Client Anxiety Through a Transaction is available here:
If you’re finding the pressures of legal practice difficult, LawCare provides free, confidential support to legal professionals. Visit lawcare.org.uk or call 0800 279 6888.
Conveyancing is built on process. For your clients, it’s built on emotion.
By the time a transaction starts to slow, most people have already spent weeks worrying; about timings, about money, about whether everything will fall apart at the last hurdle.
That anxiety doesn’t disappear. It builds, and sooner or later, it comes to you.
According to Landmark Information Group’s 2026 market research, the average transaction takes 123 days from instruction to completion. Conveyancers spend 41% of their working day chasing or being chased for updates. And 42% cite slow transaction times as their number one professional frustration.
Behind every one of those delays is a client who doesn’t fully understand what’s happening, why it’s taking so long, or whether it’s still going to complete at all. That uncertainty is where anxiety takes hold.
Mental Health Awareness Week feels like the right moment to address this directly; not with platitudes, but with something practical.
What the guide covers
We’ve put together a free guide: Managing Client Anxiety Through a Transaction. It’s written for conveyancers who want to manage the human side of a transaction as competently as the legal side, without it consuming more of your day than it already does.
The guide covers five areas:
- Why delays hit clients so hard: and why the anxiety response is rational, not irrational
- What anxious clients actually need: which is often not what they say they need
- Communication habits that reduce anxiety without adding to your workload
- Looking after yourself: because practitioner wellbeing matters too, and it’s under-discussed in this industry
- A quick-reference checklist: a clean pull-out you can keep to hand or share with your team
This isn’t a therapy guide, and it isn’t a sales presentation. It’s the kind of thing you might work through with a colleague over coffee – practical, direct, and grounded in how conveyancing actually works.
Why we wrote it
Delays aren’t always avoidable. But the anxiety they create often is… or at least, it can be reduced significantly with the right communication habits and a clear head about what clients actually need from you.
That’s a conversation worth having, and Mental Health Awareness Week is a good prompt to have it.
Managing Client Anxiety Through a Transaction is free to access: no form to fill in, no follow-up sequence.
Uncertainty isn’t new to the housing market, but in 2026 it feels closer to the surface.
Affordability pressures, shifting mortgage conditions, and broader economic headwinds mean buyers and sellers are hesitating for longer and thinking harder before committing.
That hesitation has a knock-on effect for conveyancers. Transactions take longer to progress, confidence can fluctuate mid-process, and the risk of late-stage disruption increases.
In a recent podcast conversation, OneSearch Managing Director Liz Jarvis was joined by Millar & Bryce Managing Director Richard Hepburn to explore how that uncertainty is showing up in today’s market, and why one factor matters more than most when it comes to keeping transactions on track: clear, upfront information about the property.
Confidence is built early, or it isn’t built at all.
When buyers feel uncertain – about affordability, their finances, or the property itself – they pause. And when transactions pause, momentum is lost.
As Liz puts it: “The biggest thing that drives the market is how confident people feel.”
For conveyancers, this makes the early stages of a transaction critical. The more unknowns that sit unresolved at the start, the greater the chance they resurface later as friction, delay, or a deal-breaker. Upfront information helps remove that uncertainty sooner, before emotional and financial investment deepens.
A slower market doesn’t automatically mean weaker transactions.
An important distinction worth holding onto: a quieter market doesn’t automatically mean poorer outcomes. As Liz notes, “What we’re seeing now is fewer buyers, but they’re committed buyers.”
Those still active are people who need to move, not casual browsers. That means transactions are often more likely to complete, but only if unexpected issues don’t surface late in the journey.
Time is where risk creeps in.
Longer transaction timelines give uncertainty more room to grow. The more time that passes between offer and completion, the more chance there is for circumstances to change, priorities to shift, or doubts to set in. In England and Wales, where extended timelines are already the norm, that window of vulnerability is wider than most.
Why upfront information matters now.
Upfront information isn’t about adding friction at the start of a transaction. It’s about helping buyers and sellers make informed decisions sooner, so they commit with confidence rather than assumptions.
Liz summarises it simply: “It’s allowing people to get access to information around the property… before they move further into the process.”
When clarity comes late, trust erodes quickly. When it comes early, transactions tend to feel calmer, more predictable, and more resilient.
If keeping transactions on track matters to your firm this year, the full conversation with Liz and Richard is worth twenty-five minutes of your time.
👉 Watch or listen here:
The first quarter of the year is always a pressure test for conveyancing teams.
Instructions from January are hitting their critical middle stage, client patience is thinning, and the industry’s average instruction-to-completion time of 123 days means the calendar is already working against you.
But in 2026, there’s a sharper edge to that pressure. It isn’t just workload – it’s the compounding effect of unreliable information. Missing details, inconsistent datasets, and errors that should never have made it through create a different kind of drag: one that’s harder to plan for and harder to explain to clients.
At the core of most preventable delays lies a single, underappreciated factor: data integrity.
Conveyancers are absorbing the cost of poor data.
Research shows conveyancers now spend 41% of their working day following up on updates, correcting inconsistencies, or chasing missing details – all consequences of inaccurate or incomplete data reaching them in the first place.
That’s not a workflow problem. It’s a data problem presenting as a workflow problem.
When so much time is consumed fixing issues that shouldn’t exist, the knock-on effects are predictable: slower progress, more enquiries, frustrated clients, and a rising risk of transactions falling through. And even a single misallocated or incorrect data point can derail what should be a straightforward case.
Why this matters more than most realise.
Across the sector, Landmark research has identified the data challenges that consistently create friction for conveyancing firms: poor system integration and interoperability (cited by 37% of firms), security and compliance concerns (37%), legacy systems and limited IT bandwidth (36%), and inconsistent formats that make data difficult to reconcile.
Each of these feeds the same outcome: fragmented files, unexpected queries, and delays that compound across complex chains.
The rise of digital tools has brought genuine efficiencies – 78% of firms now use AI to assist fee earners – but technology is only as reliable as the information feeding it. Better tools with unreliable data still produce unreliable outcomes.
What conveyancers actually need.
The conveyancers who handle high-pressure periods most effectively aren’t necessarily those with the fastest turnaround times. They’re the ones who aren’t constantly firefighting.
What makes the difference, consistently, is information that arrives complete, accurate, and early enough to act on. The evidence backs this up: 73% of conveyancers say early insights give buyers more confidence, 69% say it speeds up the transaction overall, and 61% say it reduces the number of enquiries raised.
Clear, early data doesn’t add friction at the start of a transaction – it removes it from everywhere else.
When data goes wrong, the ripple is wide.
The consequences of poor-quality data rarely stay contained. A minor discrepancy caught late can collapse a deal. Incorrect property attributes introduce risk for buyers. Outdated environmental data can expose clients to liabilities they weren’t warned about. Extra enquiries lengthen timelines and increase administrative load. And throughout, the conveyancer’s professional reputation absorbs the strain.
In a market where clients expect clarity and estate agents are monitoring progress closely, even small data failures carry outsized consequences.
What a good data partnership looks like in practice.
The strongest advantage a search provider can offer in 2026 isn’t speed alone – it’s accuracy you can rely on, delivered early enough to change outcomes rather than just document them.
That means verified, consistently reliable datasets. It means reducing the time spent on avoidable administrative work. It means insights that support better client conversations, not ones that generate more questions. And it means acting as a genuine extension of the conveyancing team – not a detached supplier that creates extra steps.
With caseloads under pressure and timelines stretching, the difference between a partner and a vendor is whether they make your workload lighter or heavier.
For conveyancers navigating a demanding market, data integrity isn’t a technical concern sitting somewhere in the background – it’s the foundation every smooth transaction is built on.