SRA AML report: an uploaded bank statement still needs an explanation

The brief

The SRA’s 2025/26 AML report records 966 compliance assessments and a fall in the reported non-compliant proportion from 32.4% to 21.9%. These are supervisory findings, not a population survey. Read the report.

Our analysis focuses on a practical distinction in client work: receiving a document and assessing what it proves are separate steps. A bank statement may show that money is available without explaining how it accumulated. The matter record should connect the question asked, evidence received, unresolved points and reason for acceptance. Test that connection on one completed file. A reviewer should be able to identify the reasoning without asking the original fee-earner to reconstruct it from memory or search through an unstructured collection of attachments.

The full record

The report, published on 22 October, covers 6 April 2025 to 5 April 2026. Its supervision is risk-based. Engagement totals can include more than one engagement with a firm. The SRA reports that, where documents had been gathered, source of funds had not been scrutinised in 18% of files reviewed. SRA report: scope, supervision and source of funds.

Our analysis: ask what the evidence explains

Consider a hypothetical property purchase funded from a savings account. A balance can answer whether funds are available. It may leave unanswered how they were accumulated and whether the explanation fits the matter. The point of the review is to identify which question remains open, then obtain proportionate evidence that answers it.

Keep the request specific enough for the client to understand. Explain the information needed and the relevant period. A succession of broad requests for “more documents” can create a large file without resolving the original question.

Connect the answer to the decision

For each important evidence item, record what it supports and any limitation. Identify who reviewed it, what follow-up was required and why the final position was accepted. Where the account changes during the exchange, retain the earlier explanation and the reason for the change.

This does not require a long essay for every attachment. It requires enough context for another responsible person to understand the judgement. The appropriate depth depends on the actual risk and circumstances, which this article cannot determine for an individual matter.

Test the point at which work proceeds

Choose a completed file and identify the moment at which the team treated the checks as sufficient. Compare that moment with the date of the last unresolved question. If the records disagree, establish what actually happened before describing the file as complete.

Then run a fictional case with an unanswered question at the proposed completion point. Check who can pause progress, who may authorise an exception if one is permitted, and what the next person handling the matter can see. A status field should have a defined meaning that the team can explain.

Read the statistics at their proper scale

The reported change is 10.5 percentage points, calculated by subtracting 21.9 from 32.4. It should not be described as a ten-percent reduction in money laundering or proof that a particular tool improved compliance. The report concerns assessed controls and supervisory work. Underlying SRA figures.

For a firm, the useful next step is to inspect the reasoning in a small, deliberately selected set of files and document the limits of that review. An attachment count measures documents collected. A reasoned assessment explains why the matter was allowed to proceed.

Related reading: AML supervision and retrievable records.

Read the SRA annual report published 22 October 2026. Reporting period: 6 April 2025–5 April 2026. Supervision is risk-based; engagements are not unique firms. Percentage-point change is our arithmetic. File-review proposal is unperformed editorial analysis.

1. SRA: Anti-Money Laundering Annual Report 2025–26, 22 October 2026