Client Funds Management
For Solicitors
Client Funds Management
Indemnity, Compliance and Notification Provisions
E-Solicitors Legal Services Marketplace
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Mandatory Client Money Compliance
Client Accounts | SRA Accounts Rules | COFA | Safeguarding
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Version 2.0 - January 2026
England and Wales
Important Notice to Solicitors
- YOU INDEMNIFY THE PLATFORM FOR ALL MATTERS RELATING TO YOUR MANAGEMENT OF CLIENT FUNDS. YOU MUST NOTIFY THE PLATFORM OF ANY BREACH OF CLIENT MONEY RULES.
Client Money is Sacrosanct
The protection of client money is one of the most fundamental obligations of a solicitor. Breaches of client money rules are among the most serious regulatory failures and can result in intervention, striking off, and criminal prosecution.
Platform's Position
The Platform:
Does NOT hold, receive, or process client money
Does NOT operate client accounts
Does NOT have any role in your client money arrangements
Is NOT responsible for your SRA Accounts Rules compliance
Is NOT your COFA or responsible for your financial compliance
Your Indemnity Obligations
🛡 INDEMNITY: You indemnify the Platform for ALL claims arising from your client money handling
🛡 INDEMNITY: You indemnify the Platform for SRA Accounts Rules breaches
🛡 INDEMNITY: You indemnify the Platform for client fund losses or shortfalls
🛡 INDEMNITY: You indemnify the Platform for regulatory action relating to client money
🛡 INDEMNITY: You indemnify the Platform for Compensation Fund claims
Notification Requirements
🔔 NOTIFY PLATFORM: You must notify the Platform IMMEDIATELY of any material breach of client money rules
🔔 NOTIFY PLATFORM: You must notify the Platform of any SRA investigation into client money
🔔 NOTIFY PLATFORM: You must notify the Platform of any client money shortfall
🔔 NOTIFY PLATFORM: You must notify the Platform of any intervention or conditions relating to client money
- Failure to notify may itself be a breach of these Terms and trigger additional indemnity obligations.
Contents
Part A: General Provisions
-
Definitions
-
Platform Status
-
Your Status and Obligations
-
Scope of This Agreement
Part B: Sra Accounts Rules Compliance
-
SRA Accounts Rules 2019
-
Client Money Definition
-
Client Account Requirements
-
Keeping Client Money Separate
-
Client Money Receipts and Payments
-
Interest on Client Money
Part C: Governance and Oversight
-
COFA Requirements
-
Accounting Systems and Controls
-
Reconciliations
-
Accountant's Reports
-
Record Keeping
Part D: Third Party Managed Accounts
-
TPMA Arrangements
-
TPMA Requirements
Part E: Freelance Solicitors
-
Client Money Restrictions
-
Alternative Arrangements
Part F: Aml and Client Money
-
Source of Funds Verification
-
Suspicious Transactions
-
Third Party Payments
Part G: Fca Requirements
-
When FCA Applies
-
Client Assets Rules
Part H: Breach Notification
-
Immediate Notification Events
-
Prompt Notification Events
-
Notification Procedure
-
Ongoing Reporting
Part I: Indemnity Provisions
-
General Client Money Indemnity
-
Indemnity for SRA Breaches
-
Indemnity for Client Losses
-
Indemnity for Regulatory Action
-
Indemnity for Third Party Claims
-
Scope and Survival
Part J: Platform Remedies
-
Suspension
-
Termination
-
Reporting to Regulators
Part K: General Provisions
-
Warranties
-
Insurance
-
Governing Law
Schedules
Schedule 1: Client Money Compliance Declaration
Schedule 2: Breach Notification Form
Schedule 3: Client Money Compliance Checklist
Schedule 4: COFA Confirmation
Schedule 5: Indemnity Acknowledgment
Part A: General Provisions
- Definitions
1.1 In this Agreement:
'Accountant's Report' means the report required under SRA Accounts Rules Rule 12.
'Authorised Body' means a body authorised by the SRA to provide legal services.
'Claim' means any claim, action, proceeding, demand, liability, loss, damage, cost, or expense.
'Client Account' means an account at a bank or building society in the name of the firm and designated as a client account.
'Client Money' means money held or received for a client or as trustee, excluding money held or received for payment of your own fees or disbursements already incurred.
'COFA' means Compliance Officer for Finance and Administration.
'Compensation Fund' means the SRA Compensation Fund.
'Indemnified Parties' means the Platform, its parent companies, subsidiaries, affiliates, directors, officers, employees, and agents.
'Intervention' means intervention by the SRA into your practice.
'Losses' means all losses, liabilities, damages, costs, expenses (including legal fees), fines, penalties, and other amounts.
'Office Account' means an account for your own money, not client money.
'Platform' means [Platform Name], operated by [Company Name].
'SRA Accounts Rules' means the SRA Accounts Rules 2019 (as amended).
'Third Party Managed Account' or 'TPMA' means an account held by a third party in which client money may be held in accordance with SRA Rules.
'You/Your' means the solicitor or authorised body accepting these Terms.
- Platform Status
2.1 The Platform:
(a) Is a technology marketplace facilitating
introductions;
(b) Does NOT hold, receive, or process Client
Money;
(c) Does NOT operate Client
Accounts;
(d) Does NOT receive payments intended for client
accounts;
(e) Is NOT regulated by the
SRA;
(f) Has NO role in your client money
arrangements;
(g) Is NOT responsible for your SRA Accounts Rules
compliance;
(h) Is NOT your COFA or involved in your financial compliance.
2.2 All Platform fees are payable to the Platform's own accounts and are NOT Client Money.
- Your Status and Obligations
3.1 You are solely responsible for:
(a) Compliance with SRA Accounts
Rules;
(b) Proper handling of all Client
Money;
(c) Maintaining compliant Client
Accounts;
(d) COFA appointment and oversight (if applicable
);
(e) Obtaining Accountant's
Reports;
(f) All record keeping for client
money;
(g) Reporting breaches to the
SRA;
(h) Notifying the Platform of relevant breaches.
- Scope of This Agreement
4.1 This Agreement covers:
(a) Your compliance obligations regarding Client
Money;
(b) Your notification obligations to the
Platform;
(c) Your indemnity obligations to the
Platform;
(d) Platform remedies for breaches.
Part B: Sra Accounts Rules Compliance
⚖ LEGAL REQUIREMENT: The SRA Accounts Rules 2019 govern how solicitors must handle Client Money. Breach is a serious regulatory matter.
- SRA Accounts Rules 2019
5.1 You warrant that you comply with all SRA Accounts Rules, including:
Rule
Requirement
Key Obligations
Rule 2
Client money must be kept safe
Safeguard all client money
Rule 2.1
Keep client money separate
Never mix with your own money
Rule 2.2
Identify client money promptly
Identify receipt of client money
Rule 2.3
Pay into client account promptly
No undue delay in banking
Rule 2.4
Withdraw only when permitted
Only for proper purposes
Rule 2.5
Properly account to clients
Accurate client ledgers
Rule 3
Client accounts requirements
Use authorised banks
Rule 4
Client money receipts
Proper handling procedures
Rule 5
Client money withdrawals
Authorisation and records
Rule 7
Client accounting records
Proper records maintained
Rule 8
Reconciliations
Monthly reconciliations
Rule 12
Accountant's reports
Annual reporting requirements
- Client Money Definition
6.1 Client Money includes:
(a) Money held on behalf of
clients;
(b) Money held as
trustee;
(c) Payments on account of costs before bills
delivered;
(d) Money held for disbursements not yet
paid;
(e) Money held for third parties in connection with client matters.
6.2 Client Money does NOT include:
(a) Money paid for fees already
billed;
(b) Money for disbursements already
incurred;
(c) Money agreed to be held in your office account.
- Client Account Requirements
7.1 You warrant that your Client Account(s):
(a) Are held at an authorised UK bank or building
society;
(b) Are designated as a 'client account
';
(c) Are in the name of the firm or authorised
body;
(d) Are not used for any other
purpose;
(e) Are properly authorised and
controlled;
(f) Are protected from your own creditors.
7.2 You must maintain:
(a) Adequate client account
capacity;
(b) Proper bank mandates and
authorities;
(c) Appropriate signatories and
controls;
(d) Separation from office account(s).
- Keeping Client Money Separate
8.1 You warrant that
you
Never:
(a) Use client money for your own
purposes;
(b) Mix client money with your own
money;
(c) 'Borrow' from client
account;
(d) Use one client's money for
another;
(e) Pay personal expenses from client
account;
(f) Treat client money as available to you.
- Using client money for your own purposes is theft and may result in criminal prosecution, intervention, and striking off.
- Client Money Receipts and Payments
9.1 For receipts, you must:
(a) Identify client money promptly on
receipt;
(b) Pay into client account without
delay;
(c) Ensure payment into correct client
ledger;
(d) Obtain and retain evidence of receipt.
9.2 For payments, you must:
(a) Only withdraw for permitted
purposes;
(b) Ensure sufficient funds in client
ledger;
(c) Properly authorise all
withdrawals;
(d) Maintain audit trail for all payments.
- Interest on Client Money
10.1 Under SRA Accounts Rules Rule 2.2:
(a) You must account to clients for interest (where fair and reasonable
);
(b) You must have a policy on payment of
interest;
(c) The policy must be fair to
clients;
(d) You must inform clients of the policy.
Part C: Governance and Oversight
- COFA Requirements
11.1 If you are an Authorised Body, you must have a COFA who:
(a) Is approved by the
SRA;
(b) Has appropriate seniority and
authority;
(c) Has access to all relevant
information;
(d) Reports to management on
compliance;
(e) Is responsible for SRA Accounts Rules
compliance;
(f) Has sufficient resources and time.
11.2 COFA responsibilities include:
(a) Ensuring compliance with SRA Accounts
Rules;
(b) Ensuring adequate accounting
systems;
(c) Monitoring
reconciliations;
(d) Reporting breaches to the
SRA;
(e) Oversight of Accountant's Reports.
11.3 If you are a sole practitioner or freelance solicitor, you bear COFA responsibilities personally.
- Accounting Systems and Controls
12.1 You must maintain:
(a) Proper accounting systems for client
money;
(b) Accurate client ledgers for each
client;
(c) Clear separation of client and office
accounts;
(d) Adequate internal
controls;
(e) Authorisation procedures for
payments;
(f) Audit trails for all transactions.
12.2 Systems must:
(a) Be appropriate for your size and
complexity;
(b) Allow identification of all client money at any
time;
(c) Enable reconciliations to be
performed;
(d) Support preparation of Accountant's Reports.
- Reconciliations
13.1 Under SRA Accounts Rules Rule 8, you must:
(a) Reconcile client account at least every 5
weeks;
(b) Compare client account balance to client ledger
balances;
(c) Identify and resolve all differences
promptly;
(d) Maintain records of
reconciliations;
(e) Report material discrepancies.
13.2 Reconciliation must show:
(a) Balance per bank
statement;
(b) Unpresented cheques and
lodgements;
(c) Adjusted bank
balance;
(d) Total of client ledger
balances;
(e) Any difference and explanation.
- Accountant's Reports
14.1 Under SRA Accounts Rules Rule 12:
(a) You must obtain an Accountant's Report if you hold client
money;
(b) Report must be prepared by a qualified reporting
accountant;
(c) Report period is normally 12
months;
(d) Report must be delivered to SRA within 6 months of period
end;
(e) Report must identify any breaches.
14.2 You warrant that:
(a) You obtain Accountant's Reports as
required;
(b) You cooperate fully with reporting
accountants;
(c) You address any issues raised in
reports;
(d) You report qualified opinions to the
SRA;
(e) You notify the Platform of material issues.
- Record Keeping
15.1 You must maintain records of:
(a) All client account
transactions;
(b) Individual client
ledgers;
(c) Client account
reconciliations;
(d) Bank statements and
vouchers;
(e) Authorisations and
approvals;
(f) Accountant's Reports.
15.2 Records must be:
(a) Retained for at least 6
years;
(b) Readily
accessible;
(c) Available to SRA on
request;
(d) Available to reporting accountants.
Part D: Third Party Managed Accounts
- TPMA Arrangements
16.1 If you use a
Third Party
Managed Account:
(a) The TPMA must comply with SRA
requirements;
(b) You remain responsible for client money
protection;
(c) Client money in TPMA is still client
money;
(d) You must have a written agreement with the TPMA
provider;
(e) You must notify clients of TPMA arrangements.
- TPMA Requirements
17.1 The TPMA arrangement must ensure:
(a) Client money is
ring-fenced;
(b) Client money is protected from provider
insolvency;
(c) You can identify amounts held for each
client;
(d) Clients are informed of the
arrangements;
(e) You can comply with all SRA
requirements;
(f) SRA and reporting accountants have appropriate access.
Part E: Freelance Solicitors
- Client Money Restrictions
18.1 If you are a Freelance Solicitor:
(a) You CANNOT hold client
money;
(b) You CANNOT maintain a client
account;
(c) You CANNOT receive client
money;
(d) All client payments must go to the instructing entity or client.
- Freelance Solicitors cannot hold client money. Breach is a serious regulatory matter.
- Alternative Arrangements
19.1 As a Freelance Solicitor, you must ensure:
(a) Clients pay the instructing firm
directly;
(b) Or payments are made to a TPMA in appropriate
cases;
(c) Or payments are made directly between
parties;
(d) You never receive or handle client money personally.
19.2 You must advise clients of these arrangements in your engagement terms.
Part F: Aml and Client Money
- Source of Funds Verification
20.1 For all client money received, you must:
(a) Verify the source of
funds;
(b) Ensure funds are not proceeds of
crime;
(c) Apply CDD to source of
funds;
(d) Document verification
steps;
(e) Be satisfied funds are legitimate.
20.2 Enhanced verification is required for:
(a) Large or unusual
payments;
(b) Payments from third
parties;
(c) Cash or near-cash
instruments;
(d) High-risk
jurisdictions;
(e) PEP-related funds.
- Suspicious Transactions
21.1 You must be alert to:
(a) Payments that do not match the client's
profile;
(b) Unusual payment
methods;
(c) Third party payments without
explanation;
(d) Requests to return funds to different
parties;
(e) Complex or unusual transaction
patterns;
(f) Pressure to complete quickly without explanation.
21.2 If you suspect money laundering:
(a) Report to your MLRO or file SAR
directly;
(b) Do NOT proceed without NCA consent if
required;
(c) Do NOT tip off the
client;
(d) Document your concerns and actions.
- Third Party Payments
22.1 Third party payments into client account require:
(a) Identification of the third
party;
(b) Understanding of the reason for third party
payment;
(c) Verification of third party's source of
funds;
(d) Consideration of money laundering
risk;
(e) Client consent and understanding.
- Third party payments are a money laundering red flag. Apply enhanced scrutiny per LSAG 2025.
Part G: Fca Requirements
- When FCA Applies
23.1 FCA client assets requirements may apply if you:
(a) Hold money in connection with FCA-regulated
activities;
(b) Conduct claims management
activities;
(c) Conduct consumer credit
activities;
(d) Are authorised by the FCA for any activities.
23.2 If FCA applies:
(a) FCA client money rules apply alongside SRA
rules;
(b) The more stringent requirement applies where
overlap;
(c) You must comply with CASS (Client Assets Sourcebook
);
(d) Additional reporting may be required.
- Client Assets Rules
24.1 FCA Client Assets (CASS) rules require:
(a) Segregation of client
money;
(b) Daily calculations and
reconciliations;
(c) Specific record-keeping
requirements;
(d) Client money reports to
FCA;
(e) Adequate arrangements acknowledgment letters.
24.2 You warrant that if FCA applies, you comply with all applicable CASS requirements.
Part H: Breach Notification
- YOU MUST NOTIFY THE PLATFORM OF CLIENT MONEY BREACHES. FAILURE TO NOTIFY IS A SEPARATE BREACH OF THESE TERMS.
- Immediate Notification Events
25.1 You must notify the Platform IMMEDIATELY (within 24 hours) of:
(a) Any client money shortfall or
deficiency;
(b) Any use of client money for your own
purposes;
(c) Any misappropriation of client
money;
(d) Any fraud involving client
money;
(e) SRA investigation into client money
matters;
(f) Any intervention or threatened
intervention;
(g) Any conditions imposed on your practice relating to client
money;
(h) Any criminal investigation relating to client
money;
(
i
) Discovery that client money was proceeds of
crime;
(j) Any freezing order affecting client accounts.
🔔 NOTIFY PLATFORM: These are critical events. Notify immediately via the Platform's urgent notification procedure.
- Prompt Notification Events
26.1 You must notify the Platform promptly (within 7 days) of:
(a) Material breaches of SRA Accounts
Rules;
(b) Qualified Accountant's
Reports;
(c) Issues identified by reporting
accountants;
(d) Material reconciliation
discrepancies;
(e) SRA enquiries about client
money;
(f) Client complaints about money
handling;
(g) COFA concerns about
compliance;
(h) Bank concerns about client account
operation;
(
i
) Any other material client money issue.
- Notification Procedure
27.1 Notifications must be:
(a) In writing (email to [designated email]
);
(b) Marked as urgent for immediate notification
events;
(c) Contain full details of the
issue;
(d) Identify the potential
impact;
(e) Describe remedial action taken or
planned;
(f) Confirm whether SRA has been
notified;
(g) Provide regular updates as situation develops.
- Ongoing Reporting
28.1 Following initial notification:
(a) Provide updates at least weekly until
resolved;
(b) Notify of any SRA or other regulatory
contact;
(c) Confirm when matter is
resolved;
(d) Provide final outcome
report;
(e) Confirm lessons learned and remedial measures.
Part I: Indemnity Provisions
- YOU FULLY INDEMNIFY THE PLATFORM FOR ALL CLIENT MONEY MATTERS.
- General Client Money Indemnity
29.1 You agree to indemnify, defend, and hold harmless the Indemnified Parties from and against all Claims and Losses arising out of or in connection with:
(a) Your handling of Client
Money;
(b) Your Client Account
arrangements;
(c) Any breach of SRA Accounts
Rules;
(d) Any client money shortfall or
deficiency;
(e) Any misappropriation of client
money;
(f) Any regulatory action relating to client
money;
(g) Any claim by any client relating to their
money;
(h) Any Compensation Fund
claims;
(
i
) Your failure to notify the Platform of breaches.
🛡 INDEMNITY: This indemnity covers ALL client money matters, regardless of whether you notified the Platform.
- Indemnity for SRA Breaches
30.1 You indemnify the Indemnified Parties against Losses arising from:
(a) Breach of SRA Accounts
Rules;
(b) SRA investigation into client
money;
(c) SRA disciplinary action for client money
breaches;
(d) Conditions imposed on your
practice;
(e) Intervention or threatened
intervention;
(f) Costs of SRA proceedings where Platform is
involved;
(g) Any regulatory fines or penalties.
- Indemnity for Client Losses
31.1 You indemnify the Indemnified Parties against Losses arising from:
(a) Client money lost or
stolen;
(b) Client money
shortfalls;
(c) Failure to account to clients for their
money;
(d) Interest not properly paid to
clients;
(e) Delays in returning client
money;
(f) Client claims for any money
issues;
(g) Client complaints to SRA or Legal Ombudsman.
- Indemnity for Regulatory Action
32.1 You indemnify the Indemnified Parties against Losses arising from:
(a) SRA
intervention;
(b) Appointment of intervention
agents;
(c) Freezing of
accounts;
(d) Criminal prosecution for theft or
fraud;
(e) Compensation Fund
payments;
(f) Law Society costs relating to
intervention;
(g) Any regulatory costs where Platform is involved.
- Indemnity for Third Party Claims
33.1 You indemnify the Indemnified Parties against Claims by:
(a) Clients whose money was
affected;
(b) Third parties claiming through
clients;
(c) Banks or financial
institutions;
(d) Other solicitors affected by your
breaches;
(e) Insurers seeking
subrogation;
(f) Any other third parties.
- Scope and Survival
34.1 The indemnities:
(a) Cover all direct
losses;
(b) Cover third party
claims;
(c) Cover regulatory fines and
penalties;
(d) Cover investigation
costs;
(e) Cover legal fees on an indemnity
basis;
(f) Cover settlement
amounts;
(g) Cover reputational damage
mitigation;
(h) Are NOT
capped;
(
i
) Survive termination of your Platform registration.
Part J: Platform Remedies
- Suspension
35.1 The Platform may immediately suspend your account if:
(a) You notify of an immediate notification
event;
(b) The Platform becomes aware of client money
concerns;
(c) SRA investigation is
announced;
(d) Intervention occurs or is
threatened;
(e) You fail to notify as
required;
(f) Material breach of these Terms occurs.
35.2 Suspension continues until:
(a) The matter is resolved to Platform's
satisfaction;
(b) Or termination
occurs;
(c) Or Platform is satisfied continuing is appropriate.
- Termination
36.1 The Platform may terminate your registration if:
(a) There is material misappropriation of client
money;
(b) SRA intervention
occurs;
(c) You are struck off or
suspended;
(d) Criminal proceedings are commenced for client money
matters;
(e) You fail to notify required
events;
(f) Material breach of these Terms occurs.
36.2 On termination:
(a) Indemnity obligations
continue;
(b) Notification obligations continue for past
matters;
(c) Cooperation obligations
continue;
(d) Outstanding fees remain payable.
- Reporting to Regulators
37.1 The Platform may report to the SRA if:
(a) You notify of serious client money
breaches;
(b) The Platform has reason to believe serious breaches
occurred;
(c) Required by law or
regulation;
(d) In the Platform's reasonable judgment, reporting is appropriate.
37.2 This is without prejudice to your own reporting obligations.
Part K: General Provisions
- Warranties
38.1 You warrant that:
(a) You comply with SRA Accounts
Rules;
(b) You maintain proper Client Accounts (unless Freelance Solicitor
);
(c) Your COFA is appropriately qualified and active (if applicable
);
(d) You perform reconciliations as
required;
(e) You obtain Accountant's Reports as
required;
(f) There are no current client money concerns or
breaches;
(g) You are not subject to conditions relating to client
money;
(h) You will notify the Platform of relevant
events;
(
i
) All information provided is true and accurate.
- Insurance
39.1 You warrant that:
(a) Your PII covers client money
claims;
(b) You are aware of policy terms regarding client
money;
(c) You have notified insurers of any client money
concerns;
(d) You will maintain adequate cover.
39.2 Failure of insurance to respond does not affect your indemnity obligations.
- Governing Law
40.1 This Agreement is governed by English law.
40.2 The courts of England and Wales have exclusive jurisdiction.
40.3 Each Indemnified Party may enforce indemnities under Contracts (Rights of Third Parties) Act 1999.
Schedule 1: Client Money Compliance Declaration
Client Money Compliance Declaration
I declare that:
Declaration
Confirmed
I comply with the SRA Accounts Rules 2019
☐
I maintain proper Client Account(s) OR I am a Freelance Solicitor and do not hold client money
☐
Client money is always kept separate from my own money
☐
I perform reconciliations at least every 5 weeks
☐
I obtain Accountant's Reports as required
☐
I have a COFA in place (if applicable) OR I am a sole practitioner/freelance
☐
There are no current client money shortfalls or concerns
☐
I am not subject to any conditions relating to client money
☐
There is no current SRA investigation into client money
☐
I will notify the Platform of any material client money issues
☐
I understand my indemnity obligations
☐
If any declaration cannot be confirmed, provide details:
Signed: _______________________________________________
Name: _______________________________________________
SRA ID: _______________________________________________
Firm (if applicable): _______________________________________________
Date: _______________________________________________
SCHEDULE 2: BREACH NOTIFICATION FORM
Client Money Breach Notification
- Complete this form for ANY client money breach or concern. Submit to [designated email].
Contact Details
Your Name: _______________________________________________
SRA ID: _______________________________________________
Firm: _______________________________________________
Contact Number: _______________________________________________
Email: _______________________________________________
Date of Notification: _______________________________________________
Nature of Issue
Issue Type
Applies
Client money shortfall
☐
Misappropriation of client money
☐
Breach of SRA Accounts Rules
☐
SRA investigation
☐
Intervention or threat of intervention
☐
Conditions on practice (client money)
☐
Qualified Accountant's Report
☐
Criminal investigation
☐
Client complaint (money)
☐
Other (specify below)
☐
Details of Issue
When did this occur/become known?
What happened?
Amount involved (if applicable): £_______________________________________________
Clients affected (number): _______________________________________________
Regulatory Notifications
Has SRA been notified? ☐ Yes ☐ No ☐ Will be notified
Date/planned date of SRA notification: _______________________________________________
Have insurers been notified? ☐ Yes ☐ No ☐ Will be notified
Remedial Action
What action has been/will be taken?
Signed: _______________________________________________
Date: _______________________________________________
Schedule 3: Client Money Compliance Checklist
Monthly/Regular Compliance Checklist
Check
Frequency
Last Completed
By
Client account reconciliation performed
Every 5 weeks minimum
All client ledgers balanced
Ongoing
No debit balances on client ledgers
Ongoing
Client money only used for permitted purposes
Ongoing
Receipts paid to client account promptly
Ongoing
Withdrawals properly authorised
Ongoing
Records properly maintained
Ongoing
Interest properly accounted for
As arising
COFA review completed (if applicable)
Regularly
Staff trained on client money
Annually
Annual Compliance Checklist
Check
Last Completed
Next Due
Accountant's Report obtained
Accountant's Report submitted to SRA (if required)
Issues from Accountant's Report addressed
Client money policy reviewed
Interest policy reviewed
Bank mandate reviewed
Signatories confirmed current
Training records updated
SCHEDULE 4: COFA CONFIRMATION
COFA Confirmation (Authorised Bodies Only)
This confirmation is provided by the COFA of the Authorised Body.
COFA Details
COFA Name: _______________________________________________
SRA ID: _______________________________________________
Date of SRA Approval as COFA: _______________________________________________
Firm Name: _______________________________________________
Firm SRA ID: _______________________________________________
COFA Confirmation
Confirmation
Confirmed
I am the approved COFA for this firm
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I have appropriate authority to fulfil the COFA role
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I have access to all relevant financial information
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I have sufficient time and resources for COFA duties
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The firm complies with SRA Accounts Rules
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Reconciliations are performed as required
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Accountant's Reports are obtained as required
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There are no material client money concerns currently
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I will ensure the Platform is notified of relevant issues
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Signed: _______________________________________________
Date: _______________________________________________
SCHEDULE 5: INDEMNITY ACKNOWLEDGMENT
Acknowledgment of Indemnity Obligations - Client Funds
I acknowledge and confirm that:
Acknowledgment
Confirmed
I am solely responsible for compliance with SRA Accounts Rules
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The Platform has no role in my client money arrangements
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I indemnify the Platform for all client money claims
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I indemnify the Platform for SRA Accounts Rules breaches
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I indemnify the Platform for client money shortfalls
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I indemnify the Platform for regulatory action (client money)
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I indemnify the Platform for Compensation Fund claims
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I must notify the Platform IMMEDIATELY of serious breaches
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I must notify the Platform promptly of other material issues
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Failure to notify is a separate breach of these Terms
☐
The indemnities are NOT capped
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The indemnities survive termination
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I understand the Platform may report serious matters to SRA
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I have adequate PII covering client money claims
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Signed: _______________________________________________
Name: _______________________________________________
SRA ID: _______________________________________________
Firm (if applicable): _______________________________________________
COFA (if different): _______________________________________________
Date: _______________________________________________
Document Information
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Regulatory Framework
SRA Accounts Rules 2019
SRA Standards and Regulations 2019 (as amended 2025)
SRA Code of Conduct Rule 4 (Client Money and Assets)
SRA Compensation Fund Rules
Money Laundering Regulations 2017 (as amended)
Legal Sector Affinity Group Guidance 2025
Proceeds of Crime Act 2002
FCA Client Assets Sourcebook (CASS) - where applicable
Solicitors Act 1974 (intervention powers)
Contracts (Rights of Third Parties) Act 1999
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Related Documents
Platform Terms - Solicitor Indemnity and Liability V1.0
Platform Terms - SRA Compliance Validation V1.0
Platform Terms - KYC/AML Compliance V1.0
Solicitor Terms and Conditions V1.0
Privacy Policy V1.0
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Document Version: 1.0
Effective Date: January 2026
Last Updated: January 2026
Next Review: July 2026
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- CLIENT MONEY IS SACROSANCT. You are solely responsible for compliance with SRA Accounts Rules. You indemnify the Platform for ALL client money matters. You MUST notify the Platform of any material breach or concern. Misappropriation of client money is theft and may result in criminal prosecution.