EDMC Legal Limited (RMZ Law Limited)
3rd Floor, Fast Track House, Pearson Way, Thornaby, Stockton-on-Tees , TS17 6PT
Recognised body
621281

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 26 February 2026

Published date: 13 March 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

EDMC Legal Limited T/A RMZ Law Offices (the Firm), a recognised body, authorised and regulated by the Solicitors Regulation Authority (SRA) agrees to the following outcome to the investigation:

• it is fined £2,268
• to the publication of this agreement
• it will pay the costs of the investigation of £600.

Summary of Facts

We carried out an investigation into the firm following a desk-based review (DBR) by our AML Proactive Supervision team.

Our DBR identified areas of concern in relation to the firm's compliance with the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017 (MLRs 2017), the SRA Principles 2011, the SRA Code of Conduct 2011, the SRA Principles [2019], and the SRA Code of Conduct for Firms [2019].

At the time of the DBR, the firm operated under the name Raims Mahmood Zaeem Limited; the name was formally changed on 8 January 2026.

Firm-wide risk assessment (FWRA)

Between 1 January 2020 and 10 December 2025, the firm failed to have in place an adequate firm wide risk assessment (FWRA), in breach of Regulations 18(1) and 18(2) of the MLRs 2017.

Admissions

The firm admits, and the SRA accepts, that by failing to comply with the MLRs 2017 that:

• Principle 6 of the SRA Principles 2011 – which states you must behave in a way that maintains the trust the public places in you and in the provisions of legal services.
• Principle 8 of the SRA Principles 2011 – which states you must run your business or carry out your role in the business effectively and in accordance with proper governance and sound financial risk management principles.

And the firm failed to achieve:

• Outcome 7.2 of the SRA Code of Conduct 2011 – which states you have effective systems and controls in place to achieve and comply with all the principles, rules and outcomes and other requirements of the handbook, where applicable.
• Outcome 7.5 of the SRA Code of Conduct 2011 – which states you comply with legislation applicable to your business, including anti-money laundering and data protection legislation.

To the extent the conduct took place from 25 November 2019 onwards, it breached:

• Principle 2 of the SRA Principles 2019 – which states you act in a way that upholds public trust and confidence in the solicitors' profession and in legal services provided by authorised persons.
• Paragraph 2.1(a) of the SRA Code of Conduct for Firms 2019 – which states you have effective governance structures, arrangements, systems, and controls in place that ensure you comply with all the SRA's regulatory arrangements, as well as with other regulatory and legislative requirements, which apply to you.
• Paragraph 3.1 of the SRA Code of Conduct for Firms 2019 – which states that you keep up to date with and follow the law and regulation governing the way you work.

Why a fine is an appropriate outcome

The conduct showed a disregard for statutory and regulatory obligations and had the potential to cause harm, by facilitating dubious transactions that could have led to money laundering (and/or terrorist financing). This could have been avoided had the firm had a compliant FWRA in place.

It was incumbent on the firm to meet the requirements set out in the MLRs 2017. The firm failed to do so. The public would expect a firm of solicitors to comply with its legal and regulatory obligations, to protect against these risks as a bare minimum.

The SRA considers that a fine is the appropriate outcome because:

• The agreed outcome is a proportionate outcome in the public interest because it creates a credible deterrent to others and the issuing of such a sanction signifies the risk to the public, and the legal sector, that arises when solicitors do not comply with anti-money laundering legislation and their professional regulatory rules.
• There has been no evidence of harm to consumers or third parties and there is a low risk of repetition.
• The firm has assisted the SRA throughout the investigation and has shown remorse for its actions.
• The firm did not financially benefit from the misconduct.

Rule 4.1 of the Regulatory and Disciplinary Procedure Rules states that a financial penalty may be appropriate to maintain professional standards and uphold public confidence in the solicitors' profession and in legal services provided by authorised persons. There is nothing within this Agreement which conflicts with Rule 4.1 of the Regulatory and Disciplinary Rules and on that basis, a financial penalty is appropriate.

Amount of the fine

The amount of the fine has been calculated in line with the SRA's published guidance on its approach to setting an appropriate financial penalty (the Guidance).

Having regard to the Guidance, the SRA, we, and the firm agree the nature of conduct in this matter as more serious (score of three). This is because the firm's non compliance continued after it ought reasonably to have been aware that its approach was improper, particularly when the COLP submitted a FWRA declaration to the SRA in January 2020 confirming that the firm had a compliant assessment in place. A compliant FWRA has been a mandatory requirement since the MLRs 2017 came into force on 26 June 2017, and the firm should have had one in place from 1 January 2020, when it started conducting in scope work. This shows a prolonged failure to meet this obligation further elevates the seriousness of the conduct.

On 7 May 2019 (updated on 25 November 2019), we published a Warning Notice to the profession titled 'Compliance with the money laundering regulations – firm risk assessment', which made clear that a FWRA must be in writing, kept up to date, and provided to the SRA on request. In October 2019, we further updated our website with detailed guidance and information on how to prepare a FWRA, including a downloadable template. Despite these publicly available resources and the clarity of the regulatory expectations, the firm failed to have a compliant FWRA in place until December 2025.

The firm's updated 2025 FWRA acknowledges that 'RMZ Law Offices is a small high street firm. Sectoral experience suggests that firms such as this are targets for money launderers who perceive that the size and location mean a firm is less likely to have robust policies, procedures in place to detect, prevent or report financial crime.' In light of this acknowledgement, the firm's failure to maintain a compliant FWRA for more than five years exposed it to an inherent and avoidable risk of being exploited as a vehicle for laundering criminal proceeds, particularly through property transactions, a well-established area of risk in the UK.

On 22 September 2025, the COLP of the firm confirmed that the FWRA was drafted in January 2020, and subsequent correspondence between the firm and the SRA, it is believed that the COLP to have misunderstood the difference between a FWRA and client due diligence and matter specific assessments. However, the firm did provide its FWRA from January 2020, which suggests it believed it did have a risk averse document in place at the relevant time, albeit it was not considered compliant.

The COLP's failure to understand his obligations under the MLRs, including the distinctions between key AML documents such FWRA and CMRAs, is a concern. This lack of understanding not only undermines the firm's compliance framework but also indicates weaknesses in governance, oversight, and the effectiveness of the firm's overall AML controls. This has now passed and we are confident that the distinctions between each AML control document is sufficient. We also consider not having a compliant FWRA for over five years formed part of a pattern of misconduct.

The impact of harm or risk of harm is assessed as being low (score of two). This is because the firm did have a FWRA in 2020, albeit this document was non-compliant and thus left the firm vulnerable to the risks of money laundering, particularly when providing in-scope work such as conveyancing, which forms 44% of the work carried out by the firm. The firm left itself without effective arrangements in place to manage compliance with the MLRs 2017. However, potential to cause no more than minimal loss or having no more than a minimal impact.

The 'nature' of the conduct and the 'impact of harm or risk of harm' added together give a score of five. This places the penalty in Band 'B,' as directed by the Guidance, which indicates a broad penalty bracket of between 0.4% and 1.2% of the firm's annual domestic turnover. Based

on the evidence the firm has provided of its annual domestic turnover, this results in a basic penalty of £2,520.

The SRA considers that the basic penalty should be reduced to £2,268. This reflects the firm's transparency and cooperation with the AML Proactive Supervision team and AML Investigations team, along with admitting and remedying the breaches.

The firm does not appear to have made any financial gain or received any other benefit as a result of its conduct. Therefore, no adjustment is necessary, and the financial penalty is £2,268.

Publication

Rule 9.2 of the SRA Regulatory and Disciplinary Procedure Rules states that any decision under Rule 3.1 or 3.2, including a Financial Penalty, shall be published unless the particular circumstances outweigh the public interest in publication.

The SRA considers it appropriate that this agreement is published as there are no circumstances that outweigh the public interest in publication, and it is in the interest of transparency in the regulatory and disciplinary process.

Acting in a way which is inconsistent with this agreement

The firm agrees that it will not deny the admissions made in this agreement or act in any way which is inconsistent with it.

If the firm denies the admissions, or acts in a way which is inconsistent with this agreement, the conduct which is subject to this agreement may be considered further by the SRA. That may result in a disciplinary outcome or a referral to the Solicitors Disciplinary Tribunal on the original facts and allegations.

Acting in a way which is inconsistent with this agreement may also constitute a separate breach of Principles 2 and 5 of the Principles and paragraph 3.2 of the Code of Conduct for Firms.

Costs

The firm agrees to pay the costs of the SRA's investigation in the sum of £600. Such costs are due within 28 days of a statement of costs due being issued by the SRA.