An inspector does not ask whether your file is perfect. They ask four questions: do your files show a live risk based approach, can someone follow the AML judgement without asking the fee earner, are decisions consistent with your firm wide risk assessment and your policies, and can supervision, escalation and training be evidenced. The file needs to speak for itself.
Tracy Thompson has spent thirty years in the legal profession, is a Law Society accredited Lexcel assessor and consultant, a former Lexcel Panel member and a former CQS Lead Assessor, and now provides Regulation 21 independent AML audits to firms nationwide. This session closes the Conveyancing and Residential Property Conference 2026 with the auditor's view: what she actually sees when she opens a conveyancing file, and what separates a file that survives inspection from one that generates a finding.
It works through the 2026 AML changes that property teams need to notice, the SRA sector risk signals for conveyancing, and then the documents themselves. How to refresh a firm wide risk assessment so it reads like your firm and not a generic template. What policies, controls and procedures have to tell staff. Weak and defensible client and matter risk assessments set side by side with the actual wording. Source of funds against source of wealth. Client account as both a control point and a risk point. Then the Conveyancing Quality Scheme angle on file discipline, what training has to cover, how supervision gets evidenced, and an inspector ready file checklist to audit your own files against.
Key Takeaways
- The four questions an inspector asks of any file, and why the file has to answer them without the fee earner in the room
- The 2026 AML changes that matter to property teams: the refined enhanced due diligence trigger, mandatory EDD focused on FATF call for action jurisdictions, pooled client account provisions, and sterling thresholds replacing euro thresholds
- How to refresh a firm wide risk assessment so it reads like your firm rather than a template, with evidence, named controls, version control and senior management approval
- Weak against defensible client and matter risk assessments, with the actual wording for a first time buyer with a parental gift and for a company client, and why defaulting every file to medium fails
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