Colp & Cofa

AML compliance for law firms depends on understanding risk, maintaining effective policies and ensuring staff follow them. The European money laundering reforms announced in 2015 reinforced the importance of risk assessment, customer due diligence and beneficial ownership—issues that remain central to a law firm’s AML arrangements today.

The practical question is whether the learning improves the solicitor’s ability to provide competent services. An attendance certificate records participation; it does not, by itself, explain why the activity was needed or what changed afterwards.

Originally published on 29 December 2015. Updated on 8 October 2026 to reflect current SRA guidance and add practical resources for solicitors and COLPs.

How continuing competence replaced the old CPD approach

When this article was first published, solicitors were moving towards a different approach to professional development. The new system became compulsory on 1 November 2016, replacing the annual requirement to complete 16 hours of CPD.

The central change was to connect learning with the work a solicitor actually performs. Different roles, levels of experience and areas of practice create different development needs.

A solicitor taking on unfamiliar work may need detailed training and supervision. Another may need to improve communication with vulnerable clients, understand a regulatory warning or address a recurring weakness revealed by file reviews.

What does the SRA expect solicitors to do?

The SRA’s continuing competence guidance describes a process of reflection, identifying needs, planning and addressing them, recording activity and evaluating its effectiveness.

Applied to everyday practice, that means:

1. Reflect: consider the quality of your work and areas where your understanding or skills need development.
2. Identify: describe the learning need clearly and connect it to your role.
3. Plan and address: choose suitable activities and make time to complete them.
4. Record: retain useful evidence of the need, activity and resulting action.
5. Evaluate: assess whether the learning addressed the need and whether further work is necessary.

Competence extends beyond technical legal knowledge

The review should consider the whole role. Legal updates are important, but so are ethics, regulatory obligations, communication, supervision and working effectively with colleagues and clients.

A complaint may identify a need to explain advice more clearly. A file review may reveal that staff recognise a risk but do not know when to escalate it. A new system may require training on checking its output before relying on it.

Our related About Conveyancing article on learning from conveyancing client feedback and complaints explores how client experience can help identify improvements.

Choose learning that addresses the identified need

A course or webinar may be appropriate, but useful learning can also include focused research, supervised work, mentoring, discussion of a difficult matter or reviewing a completed file with an experienced colleague.

Choose the activity by reference to the problem. If a solicitor needs to improve how they explain a risk to clients, another general legal update may leave that need unresolved.

Consider the credibility, relevance and currency of the material. Afterwards, ask whether the solicitor can apply what they learned and whether any uncertainty remains.

Keep evidence that explains the learning

The SRA does not currently impose a standalone requirement to maintain a training record or document reflection. However, it regularly seeks evidence that solicitors are maintaining their competence, and its guidance recommends keeping records.

The SRA’s recording and evaluation guidance explains that a list of completed activities alone does not provide appropriate assurance that learning needs have been identified and addressed.

A useful record can be brief. It should explain the need, how it arose, the activity undertaken, what was learned and any further action.

For example:

A file review identified uncertainty about a lender’s electronic signature requirements. I reviewed the applicable instructions and registration guidance, discussed the process with my supervisor and revised the signing checklist. A follow-up review will check that the procedure is being applied correctly.

Our article on HSBC’s qualified electronic signature requirements provides a practical example of an instruction change that may prompt a learning review.

What should COLPs and managers do?

Individual solicitors retain responsibility for their competence. Firms also have responsibilities: the SRA’s guidance states that regulated firms must ensure their solicitors and registered lawyers are competent to carry out their roles.

COLPs and managers can support this through:

• Making time for reflection and relevant learning.
• Using supervision, complaints and file reviews to identify development needs.
• Checking that staff understand relevant regulatory guidance.
• Allocating responsibility for training and follow-up.
• Evaluating whether learning has improved the work.

A policy should explain how these arrangements operate in the particular firm. Our About Conveyancing guide to putting a CQS risk management policy into practice considers the connection between responsibilities, procedures and file evidence.

Use a learning and development policy to organise the process

For CQS-accredited conveyancing practices, Lexsure’s CQS CPMS Learning and Development Policy template offers a drafting starting point covering responsibilities, induction, appraisals, development plans, training activities and evaluation.

Its CQS focus should be recognised when considering it for a wider practice. Adapt the document to the firm’s roles, work and supervision arrangements.

Where reviews identify wider operational concerns, consider the firm’s CQS Risk Management Policy alongside its learning arrangements. Training and risk procedures should support each other.

Make the annual declaration on an informed basis

As part of practising certificate renewal, solicitors must make the applicable continuing competence declaration. The SRA expects them to have reflected on their work, addressed identified needs and maintained their competence across their role.

AML training should form part of the firm’s wider approach to maintaining competence. Our guide to continuing competence for solicitors explains how identifying learning needs, undertaking suitable training and evaluating its effectiveness can support that process.

Before declaring, review unresolved learning needs and the steps taken to address them. A folder of certificates may contribute evidence, but the underlying question remains: are you competent to perform the work you undertake?