The long-awaited Dentons appeal will be heard in March 2026 and is being closely watched across the profession. The outcome goes directly to the standard by which AML breaches are judged as professional misconduct.
The matter began with the SRA’s decision to bring proceedings against Dentons UK and Middle East LLP, with the case referred to the Solicitors Disciplinary Tribunal in December 2022. The hearing took place in March 2024.
The Tribunal found that there had been a breach of The Money Laundering Regulations 2007 but did not go as far as finding that there had been professional misconduct with regard to SRA Principles or the Code of Conduct. It dismissed those allegations.
The SRA appealed. On 11 March 2025 the High Court allowed that appeal, quashed the SDT’s decision and remitted the case to a fresh Tribunal panel for reconsideration. Dentons was ordered to pay the SRA’s reasonable costs of both the original proceedings and the appeal. Permission to appeal to the Court of Appeal was granted on 8 August 2025, and the hearing is listed for 24 and 25 March 2026.
What the Case Is Really About
The key issue is the threshold for professional misconduct in the context of AML failures.
The SDT’s original reasoning suggested that a breach of the Money Laundering Regulations would only amount to professional misconduct if it was also serious, culpable and reprehensible. The High Court took a different view, holding that the Tribunal had misdirected itself in applying that additional threshold.
If a breach of the AML regime can, in itself, constitute professional misconduct without a separate test of seriousness layered on top, the regulatory landscape shifts. For firms, particularly those in higher-risk sectors such as conveyancing, this affects how AML failures may be characterised and prosecuted.
Past Regulations, Present Impact
The appeal relates to an earlier regulatory regime, but its outcome is likely to shape how AML breaches are judged under the current framework. Given the increased expectations around CDD, ongoing monitoring and governance, the stakes are arguably higher now.
Why Conveyancing Firms Should Pay Attention
Property transactions continue to feature prominently in the National Risk Assessment and the SRA’s own sectoral risk assessments. The combination of client money, high-value assets and complex ownership structures makes conveyancing an area of sustained regulatory focus.
In that context, the Dentons appeal sits against a backdrop of heightened AML enforcement. The SRA has been clear that AML compliance is a priority area, and that failures will be scrutinised closely.
If the Appeal Fails: A Shift in Exposure for Firms
If Dentons’ appeal is unsuccessful, the impact for firms could be significant. It would strengthen the position that breaches of the money laundering regime can be treated as professional misconduct in their own right, even where there is no dishonesty, no client loss and limited practical impact.
That shifts the risk. The question becomes less about whether an AML failure is “serious enough” to cross a separate threshold, and more about whether non-compliance itself can trigger disciplinary findings as a matter of course. For conveyancing firms in particular, this matters. A misconduct finding can carry consequences far beyond process improvement, including further reputational damage, restriction on practicing and long-term impact on individual careers.
Whatever the outcome of the appeal, AML controls should be treated as a core element of practice risk, approached with the same discipline as the fundamental SRA Principles and Code of Conduct obligations, including honesty, integrity and acting in a way that upholds public trust and confidence in the solicitors‘ profession.