Skip to main content

Complaints About Clients

Solicitor Complaints​

About Buyers​

E-Solicitors Complaints Procedure

─────────────────────────────────────

Complaints Process and Investigation Guide​

For Solicitors and Platform Operations

─────────────────────────────────────

Version 1.0 - January 2026

England and Wales

Overview and Purpose​

This document sets out the procedure for solicitors registered on the Platform to make complaints about

buyers, and

provides guidance on the Platform's investigation process. It also provides essential guidance for solicitors on their own complaints handling obligations under SRA, Law Society, and FCA requirements.

Document Scope

This procedure covers:

How solicitors can complain to the Platform about buyer conduct

Grounds for making a complaint

How the Platform will investigate complaints

Possible outcomes and actions

Solicitor obligations for handling client complaints (regulatory guidance)

Escalation paths and external reporting

Consumer protection considerations

Vulnerable client considerations

  • This procedure is for complaints about BUYERS (clients or prospective clients). For complaints about the Platform's services, see the separate Platform Complaints Procedure. For complaints about legal services, buyers should contact the solicitor directly (see Part 5).

Key Principles

All complaints will be treated seriously and investigated fairly

Complaints will be handled confidentially where possible

The Platform will act impartially between solicitors and buyers

Regulatory obligations take precedence over commercial considerations

Suspected criminal conduct will be reported to appropriate authorities

Data protection principles will be observed throughout

Equality, diversity and inclusion principles will be applied

Vulnerable individuals will receive appropriate consideration

Contents​

Part 1: Solicitor Complaints About Buyers​

  1. Grounds for Complaint

  2. How to Make a Complaint

  3. Information Required

  4. Complaint Categories and Severity

Part 2: Platform Investigation Process​

  1. Receipt and Acknowledgment

  2. Initial Assessment

  3. Investigation Procedures

  4. Buyer's Right to Respond

  5. Investigation Outcomes

  6. Actions and Sanctions

Part 3: Serious Matters and Escalation​

  1. Criminal Conduct

  2. Regulatory Reporting

  3. Sanctions and AML Concerns

  4. Data Protection Issues

Part 4: Appeals and Review​

  1. Appeal Process

  2. External Escalation

Part 5: Solicitor Complaints Obligations​

  1. SRA Requirements for Complaints Handling

  2. Law Society Guidance

  3. Legal Ombudsman Scheme

  4. FCA Considerations

  5. Record Keeping and Reporting

Part 6: Consumer Protection and Vulnerable Clients​

  1. Consumer Rights in Complaints Context

  2. Vulnerable Client Considerations

  3. Equality, Diversity and Inclusion

Schedules​

Schedule 1: Solicitor Complaint Form

Schedule 2: Investigation Checklist (Platform Use)

Schedule 3: SRA Complaints Handling Requirements

Schedule 4: Legal Ombudsman Information

Schedule 5: Regulatory Reporting Triggers

Schedule 6: Consumer Protection Checklist

Part 1: Solicitor Complaints About Buyers​

1. Grounds for Complaint​

1.1 Solicitors may make a complaint to the Platform about a buyer in the following circumstances:

1.1.1 Fraudulent or Dishonest Conduct

Providing false identity documents or information

Attempting to use the Platform for fraudulent purposes

Misrepresenting their legal situation or needs

Identity fraud or impersonation

Providing false information about source of funds

Attempting to deceive the solicitor or third parties

1.1.2 Money Laundering or Financial Crime Concerns

Suspected money laundering activity

Refusal to provide required AML/KYC documentation

Providing documents that appear falsified

Inconsistent or implausible explanations for transactions

Red flag indicators for money laundering (per LSAG 2025)

Sanctions evasion attempts

Connections to high-risk third countries (FATF Black/Grey lists)

Unexplained third-party funding (LSAG 2025)

Beneficial ownership concealment (MORE THAN 25% threshold per LSAG 2025)

  • If you suspect money laundering, you MUST file a Suspicious Activity Report (SAR) with the National Crime Agency. Do NOT disclose this to the buyer (tipping off is a criminal offence). See Part 3 for guidance.

1.1.3 Abusive, Threatening or Harassing Behaviour

Verbal abuse or threats towards the solicitor or staff

Written abuse via Platform messaging or email

Harassment or persistent unwanted contact

Discriminatory behaviour (protected characteristics under Equality Act 2010)

Threats of violence

Stalking behaviour

1.1.4 Non-Payment or Fee Disputes

Failure to pay agreed fees without legitimate reason

Chargebacks or payment fraud

Repeated non-payment patterns

Bad faith fee disputes

ℹ Genuine fee disputes are not grounds for complaint. Buyers have the right to challenge bills through proper channels including the Legal Ombudsman. Consumer clients have additional rights under CRA 2015.

1.1.5 Breach of Platform Terms

Misuse of Platform features

Creating multiple accounts to circumvent restrictions

Providing fake reviews

Interfering with Platform operations

1.1.6 Other Serious Conduct

Providing instructions to act unlawfully

Attempting to involve the solicitor in illegal activity

Conduct that puts the solicitor at regulatory risk

Serious breach of confidentiality obligations

1.2 The following are generally NOT valid grounds for complaint:

Buyer choosing not to instruct you after initial enquiry

Buyer instructing a different solicitor

Legitimate fee disputes or bill challenges

Reasonable complaints about your services

Buyer terminating your retainer lawfully

Buyer exercising their statutory consumer rights (CRA 2015, CCR 2013)

Buyer exercising their 14-day cancellation right

2. How to Make a Complaint​

2.1 To make a complaint about a buyer, solicitors should:

2.1.1 Complete the Solicitor Complaint Form (Schedule 1) with all relevant

details;

2.1.2 Gather all supporting evidence (see clause 3

);

2.1.3 Submit the complaint via the Platform's dedicated complaints

channel;

2.1.4 Retain copies of all materials submitted.

2.2 Complaints can be submitted:

2.2.1 Online: Via the Platform's Solicitor Dashboard complaints section

2.2.2 Email: solicitor-complaints@[platform].com

2.2.3 Post: [Platform Name], Complaints Team, [Address]

2.3 For urgent matters involving immediate risk:

2.3.1 Platform Emergency Line: [Phone Number]

2.3.2 Police (if immediate danger): 999

2.3.3 Police (non-emergency): 101

3. Information Required​

3.1 When making a complaint, provide the following information:

Essential Information

☐ Your name and SRA ID

☐ Your

firm

name and SRA firm reference

☐ Buyer's name (as known to you)

☐ Buyer's Platform username or reference number

☐ Date(s) of the incident(s)

☐ Clear description of the complaint

☐ Category of complaint (from clause 1.1)

Supporting Evidence

☐ Copies of relevant communications (emails, messages, letters)

☐ Screenshots of Platform messages

☐ Copies of documents provided by buyer

☐ Evidence of falsified documents (if applicable)

☐ Record of telephone conversations (notes/recordings if lawful)

☐ Any other relevant evidence

For AML/Financial Crime Concerns

☐ Summary of red flags identified (per LSAG 2025)

☐ CDD documents provided (redacted if necessary)

☐ Source of funds/wealth documentation

☐ Third-party funding concerns (LSAG 2025)

☐ Beneficial ownership concerns (>25% threshold)

☐ Confirmation of whether SAR has been filed (DO NOT provide SAR details)

  • DO NOT include details of any SAR filing in your complaint to the Platform. Simply confirm whether a SAR has been filed. Disclosing SAR contents could constitute tipping off.

For Abusive Behaviour

☐ Exact wording of abusive communications

☐ Dates and times of incidents

☐ Names of any witnesses

☐ Impact on you and your staff

☐ Any police report references

☐ Whether any protected characteristics involved (Equality Act 2010)

4. Complaint Categories and Severity​

4.1 Complaints are categorised by severity to determine investigation priority:

CRITICAL - Immediate Risk: Threats of violence, ongoing criminal activity, imminent fraud. Target: Same day response.

HIGH - Criminal/Regulatory: Money laundering, fraud, sanctions concerns, serious harassment. Target: 2 working days.

MEDIUM - Serious Misconduct: Repeated abuse, payment fraud, false documentation. Target: 5 working days.

STANDARD - Policy Breach: Platform misuse, minor dishonesty, single incident abuse. Target: 10 working days.

LOW - General Concerns: Poor conduct not meeting other thresholds. Target: 15 working days.

4.2 Severity is assessed based on:

Risk of harm to the solicitor, staff, or third parties

Potential criminal conduct

Regulatory implications

Pattern of behaviour

Vulnerability of any parties involved

Impact on the integrity of the Platform

Part 2: Platform Investigation Process​

ℹ This section provides guidance for the Platform's Complaints Team on investigating solicitor complaints about buyers.

5. Receipt and Acknowledgment​

5.1 Upon receiving a complaint, the Platform will:

5.1.1 Log the complaint with a unique reference

number;

5.1.2 Assign an initial severity

rating;

5.1.3 Acknowledge receipt to the solicitor within 2 working

days;

5.1.4 Assign an investigator (ensuring no conflict of interest

);

5.1.5 Consider whether immediate protective action is

required;

5.1.6 Assess whether any vulnerable persons are involved.

5.2 The acknowledgment will include:

Complaint reference number

Name of assigned investigator

Expected timeline for investigation

Contact details for updates

Confirmation of any immediate actions taken

6. Initial Assessment​

6.1 The investigator will conduct an initial assessment within the target response time to:

6.1.1 Verify the complaint contains sufficient

information;

6.1.2 Confirm the solicitor is registered on the

Platform;

6.1.3 Identify the buyer and review their

account;

6.1.4 Assess whether the complaint falls within

scope;

6.1.5 Determine if immediate action is needed (account suspension, etc.

);

6.1.6 Identify if the matter should be escalated (see Part 3

);

6.1.7 Consider consumer protection

implications;

6.1.8 Assess whether any party may be vulnerable.

6.2 Initial Assessment Outcomes:

6.2.1 Proceed to full

investigation;

6.2.2 Request additional information from

solicitor;

6.2.3 Close complaint (out of scope or insufficient grounds

);

6.2.4 Immediate escalation to senior management or external authorities.

7. Investigation Procedures​

7.1 For complaints proceeding to investigation, the investigator will:

7.1.1 Evidence Gathering

☐ Review all evidence submitted by the solicitor

☐ Review Platform records (messages, transactions, account history)

☐ Review buyer's registration information

☐ Check for previous complaints about the same buyer

☐ Check for patterns across multiple solicitors

☐ Obtain any relevant third-party information (where lawful)

7.1.2 Account Review

☐ Review buyer's registration date and activity

☐ Review buyer's interaction history

☐ Check verification status and documents provided

☐ Review payment history and any disputes

☐ Check for multiple accounts

7.1.3 Investigation Record

☐ Maintain detailed investigation log

☐ Document all evidence reviewed

☐ Record all decisions and rationale

☐ Ensure audit trail is complete

  1. BUYER'S RIGHT TO RESPOND

8.1 Except in cases involving suspected criminal activity where notification could prejudice an investigation, the buyer will be:

8.1.1 Notified of the complaint (in general terms

);

8.1.2 Given the opportunity to respond within 10 working

days;

8.1.3 Informed of any actions taken against their account.

8.2 The buyer's response will be:

8.2.1 Reviewed and considered

fairly;

8.2.2 Put to the solicitor for comment (where appropriate

);

8.2.3 Included in the investigation record.

8.3 Buyer notification is NOT required where:

8.3.1 There is suspected money laundering (risk of tipping off

);

8.3.2 Police or regulatory investigation is

ongoing;

8.3.3 Notification could put anyone at

risk;

8.3.4 The complaint is clearly vexatious or unfounded.

9. Investigation Outcomes​

9.1 Following investigation, the Platform will reach one of the following conclusions:

9.1.1 Complaint Upheld: Evidence supports the complaint. Action will be taken against the buyer.

9.1.2 Complaint Partially Upheld: Some aspects are supported. Proportionate action will be taken.

9.1.3 Complaint Not Upheld: Insufficient evidence or conduct does not warrant action.

9.1.4 Inconclusive: Unable to reach a conclusion due to conflicting evidence.

9.1.5 Referral Required: Matter requires referral to external authorities.

9.2 The solicitor will be notified of the outcome in writing, including:

Summary of findings

Conclusion reached

Actions taken or proposed

Appeal rights (see Part 4)

10. Actions and Sanctions​

10.1 Where a complaint is upheld, the Platform may take one or more of the following actions:

Written Warning: First minor breach, low severity. Recorded permanently.

Temporary Suspension: Moderate breach, pending investigation. Up to 30 days.

Restrictions on Account: Repeated minor breaches, specific concerns.

Permanent Account Termination: Serious breach, criminal conduct, repeated violations.

Referral to Authorities: Criminal conduct, money laundering, fraud.

Notification to Other Solicitors: Where pattern poses risk to others.

Legal Action: Fraud, significant losses caused.

10.2 Factors considered in determining action:

Severity of the conduct

Whether the conduct was deliberate or negligent

Impact on the solicitor and others

Previous complaints or warnings

Buyer's response and any mitigating factors

Vulnerability of any parties involved

Risk of continued harm

Regulatory requirements

Part 3: Serious Matters and Escalation​

  • This section covers serious matters requiring external reporting. Solicitors and the Platform have legal obligations that override normal complaints procedures.

11. Criminal Conduct​

11.1 Where a complaint involves suspected criminal conduct, the Platform will:

11.1.1 Preserve all relevant

evidence;

11.1.2 Not alert the buyer (unless safe to do so

);

11.1.3 Consider reporting to the

police;

11.1.4 Cooperate with any police

investigation;

11.1.5 Suspend the buyer's account pending investigation (where appropriate).

11.2 Criminal conduct includes:

Fraud and attempted fraud

Identity theft

Money laundering

Threats of violence

Harassment (criminal level)

Computer misuse offences

Sanctions breaches (SAMLA 2018)

12. Regulatory Reporting​

12.1 Certain matters must be reported to regulators:

12.1.1 SRA Reporting

The Platform may report matters to the SRA where a buyer's conduct:

Involves a solicitor in regulatory breach

Raises concerns about solicitor conduct

Involves impersonation of solicitors

12.1.2 FCA Reporting

Where the Platform or solicitors become aware of:

Potential breaches of financial regulations

Matters relevant to AML supervision

Conduct by FCA-regulated persons

Issues relevant to FCA transition for legal services AML supervision

12.1.3 ICO Reporting

Data protection breaches must be reported to the ICO where:

The breach is likely to result in risk to individuals

Reporting is required within 72 hours of becoming aware

13. Sanctions and Aml Concerns​

  • If you suspect money laundering or sanctions breaches, you have legal obligations. Failure to comply is a criminal offence.

13.1 Solicitor Obligations:

13.1.1 File a Suspicious Activity Report (SAR) with the NCA if you know or suspect money

laundering;

13.1.2 Do NOT proceed with the transaction without NCA consent (DAML

);

13.1.3 Do NOT tip off the buyer about the

SAR;

13.1.4 Report sanctions

concerns

to

OFSI;

13.1.5 Check FATF

Black List

(DPRK, Iran, Myanmar) and Grey

List;

13.1.6 Document your concerns and actions taken.

13.2 LSAG 2025 Updates - What to Look For:

13.2.1 Beneficial ownership concealment (MORE THAN 25% threshold

);

13.2.2 Third-party funding without adequate

explanation;

13.2.3 Supply chain risk

factors;

13.2.4 Connections to high-risk third

countries;

13.2.5 Inconsistent source of funds/wealth explanations.

13.3 What to Include in Your Platform Complaint:

Confirm a SAR has been filed (if applicable) - do NOT provide SAR details

Describe the red flags observed (in general terms)

Confirm whether you declined or ceased to act

Confirm whether any transaction proceeded

13.4 Platform Actions:

13.4.1 Immediately suspend buyer's

account;

13.4.2 Preserve all

records;

13.4.3 Consider whether Platform has own SAR

obligation;

13.4.4 Flag buyer to other solicitors (where lawful and appropriate

);

13.4.5 Cooperate with NCA and law enforcement.

14. Data Protection Issues​

14.1 Where complaints involve data protection concerns:

14.1.1 Personal data will be processed lawfully and fairly (UK GDPR

);

14.1.2 Information will only be shared where necessary and

lawful;

14.1.3 Both parties' data protection rights will be

respected;

14.1.4 Complaints records will be retained in accordance with retention

policies;

14.1.5 Data subjects' rights will be respected (access, rectification, erasure).

14.2 Grounds for processing complaint data:

Legitimate interests (investigating complaints, protecting users)

Legal obligation (regulatory and law enforcement requirements)

Contract performance (Platform terms)

Part 4: Appeals and Review​

15. Appeal Process​

15.1 Both the solicitor and the buyer may appeal the outcome of a complaint investigation.

15.2 Grounds for Appeal:

15.2.1 Procedural unfairness in the

investigation;

15.2.2 New evidence not available during

investigation;

15.2.3 Error of fact in the

decision;

15.2.4 Disproportionate sanction.

15.3 Appeal Process:

15.3.1 Appeals must be submitted within 14 days of the

decision;

15.3.2 Appeals must be in writing, stating grounds

clearly;

15.3.3 Appeals will be reviewed by a senior manager not involved in the original

decision;

15.3.4 Appeal decisions will be communicated within 20 working

days;

15.3.5 Appeal decisions are final.

16. External Escalation​

16.1 If dissatisfied with the Platform's handling of a complaint, parties may:

For Solicitors:

Raise concerns with the SRA (if the Platform's conduct affects regulatory compliance)

Seek independent legal advice

Consider civil remedies (if appropriate)

For Buyers:

Contact Trading Standards

Seek ADR (Alternative Dispute Resolution) where available

Consider civil remedies

ℹ The Legal Ombudsman does NOT handle complaints about the Platform (as it is not a legal services provider). The Legal Ombudsman only handles complaints about legal services provided by solicitors.

Part 5: Solicitor Complaints Obligations​

ℹ This section provides guidance for solicitors on their regulatory obligations for handling complaints FROM clients.

17. Sra Requirements for Complaints Handling​

17.1 SRA Code of Conduct for Firms (Rule 7) requires:

17.1.1 A written complaints

procedure;

17.1.2 That the procedure is brought to clients' attention at the time of

engagement;

17.1.3 That complaints are dealt with promptly, fairly, and free of

charge;

17.1.4 That the Legal Ombudsman is signposted to complainants.

17.2 Required Elements of a Complaints Procedure:

☐ Clear explanation of how to make a complaint

☐ Named individual responsible for complaints

☐ Timescales for acknowledgment (recommend 5 working days)

☐ Timescales for investigation and response (8 weeks maximum)

☐ Escalation process within the firm

☐ Information about the Legal Ombudsman (including time limits)

☐ Information about the SRA

☐ Information about any other ADR providers

17.3 SRA Principles Relevant to Complaints:

Principle 2 (Public Trust): Handle complaints in a way that maintains public confidence

Principle 4 (Honesty): Be honest in responding to complaints

Principle 6 (EDI): Handle complaints without discrimination

Principle 7 (Client Best Interests): Resolve complaints fairly

17.4 Client Information Requirements - At engagement, you must tell clients:

☐ Your complaints procedure

☐ How to make a complaint

☐ Their right to complain to the Legal Ombudsman

☐ Time limits for complaining to the Legal Ombudsman

☐ Contact details for the Legal Ombudsman

18. Law Society Guidance​

18.1 The Law Society recommends best practice for complaints handling:

Acknowledge complaints within 5 working days

Investigate thoroughly and objectively

Keep complainants informed of progress

Respond substantively within 8 weeks

Offer resolution where appropriate

Learn from complaints to improve service

Maintain complaints log and analyse trends

18.2 Accreditation Requirements:

Lexcel

: Documented complaints policy, training, regular review

CQS: Specific complaints handling requirements for conveyancing

WIQS: Complaints data reporting

19.1 The Legal Ombudsman (

LeO

) handles complaints about legal services not resolved by the law firm.

19.2 Time Limits for Legal Ombudsman Complaints:

  • These time limits are strict and were updated in 2021:

19.2.1 Within 1 YEAR of the date of the act or omission complained about (or 1 year from when the complainant should reasonably have known about it

);

19.2.2 Within 6 YEARS of the act or omission; AND

19.2.3 Within 6 MONTHS of the solicitor's final response to the complaint.

19.3 Legal Ombudsman Contact Details:

Website: www.legalombudsman.org.uk

Email: enquiries@legalombudsman.org.uk

Phone: 0300 555 0333

Post: PO Box 6167, Slough SL1 0EH

19.4 What the Legal Ombudsman Can Do:

Investigate complaints about poor service

Award compensation up to £50,000

Direct refund of fees

Direct the solicitor to put things right

Direct an apology

19.5 What the Legal Ombudsman Cannot Do:

Investigate conduct issues (that is the SRA's role)

Strike off solicitors

Award unlimited compensation

Make decisions outside their jurisdiction

20. Fca Considerations​

20.1 For firms conducting FCA-regulated activities (e.g., insurance mediation, certain investment activities), additional complaints requirements apply under FCA rules (DISP).

20.2 FCA Complaints Requirements:

Written acknowledgment within 5 working days

Final response within 8 weeks

Signposting to Financial Ombudsman Service (FOS)

Complaints reporting to FCA

20.3 Financial Ombudsman Service:

Website: www.financial-ombudsman.org.uk

Phone: 0800 023 4567

20.4 FCA Transition for AML: Solicitors should prepare for FCA supervision of AML compliance, which may include additional complaints reporting requirements.

  • If your firm conducts FCA-regulated activities, ensure you understand and comply with both SRA and FCA complaints requirements.

21. Record Keeping and Reporting​

21.1 Solicitors must maintain complaints records including:

☐ Date complaint received

☐ Complainant details

☐ Nature of complaint

☐ How complaint was investigated

☐ Outcome and any remedial action

☐ Date of final response

☐ Whether referred to Legal Ombudsman

☐ Outcome of any Legal Ombudsman investigation

21.2 Complaints data should be:

Analysed regularly for trends

Reported to firm management/compliance

Used to identify training needs

Used to improve service delivery

Reported to SRA as required

21.3 COLP Reporting - The COLP should:

Monitor complaints handling

Report significant complaints to management

Report material failures to the SRA

Ensure learnings are implemented

Part 6: Consumer Protection and Vulnerable Clients​

22. Consumer Rights in Complaints Context​

22.1 Consumer Protection Legislation applies to complaints involving consumer clients:

Consumer Rights Act 2015

Services must be performed with reasonable care and skill

Services must be completed within agreed timescale

Consumer has right to repeat performance or price reduction

Unfair terms in consumer contracts are not binding

Consumer Contracts Regulations 2013

Consumer may have exercised 14-day cancellation right

Complaints about information not provided pre-contract

Complaints about cancellation process

Digital Markets, Competition and Consumers Act 2024

Complaints about drip pricing (hidden fees added later)

Complaints about mandatory costs not disclosed upfront

Complaints about unfair commercial practices

22.2 When handling complaints involving consumer rights:

22.2.1 Determine whether complainant is a consumer or

business;

22.2.2 Apply appropriate consumer

protections;

22.2.3 Consider whether statutory remedies

apply;

22.2.4 Be aware of Trading Standards jurisdiction.

23. Vulnerable Client Considerations​

23.1 In accordance with SRA Code Rules 3.4 and 6.2, special consideration must be given to complaints involving vulnerable clients.

23.2 Vulnerability factors include:

Age (older or younger clients)

Disability (physical, sensory, or learning)

Mental health conditions

Mental capacity issues (Mental Capacity Act 2005)

Language barriers

Bereavement or emotional distress

Financial difficulties

Other circumstances affecting engagement

23.3 When a complaint involves a potentially vulnerable buyer:

23.3.1 Consider whether the buyer's conduct may be explained by

vulnerability;

23.3.2 Apply a higher threshold before taking adverse

action;

23.3.3 Consider whether reasonable adjustments should have been

made;

23.3.4 Involve appropriate support where

possible;

23.3.5 Document vulnerability considerations in the investigation.

23.4 When a complaint is made BY a vulnerable buyer (about the solicitor):

23.4.1 Provide information in accessible

format;

23.4.2 Allow additional time for

responses;

23.4.3 Permit support person to

assist;

23.4.4 Consider face-to-face or telephone

communication;

23.4.5 Make reasonable adjustments at no extra cost.

  1. EQUALITY, DIVERSITY AND INCLUSION

24.1 In accordance with SRA Principle 6 and the Equality Act 2010, complaints handling must be non-discriminatory.

24.2 Protected Characteristics (Equality Act 2010):

Age

Disability

Gender reassignment

Marriage and civil partnership

Pregnancy and maternity

Race

Religion or belief

Sex

Sexual orientation

24.3 EDI in Complaints Handling:

24.3.1 No complainant should be treated less favourably due to protected

characteristics;

24.3.2 Reasonable adjustments must be made for disabled

complainants;

24.3.3 Complaints about discriminatory treatment must be taken

seriously;

24.3.4 EDI data on complaints should be monitored and

reported;

24.3.5 Staff handling complaints should receive EDI training.

24.4 If a complaint involves alleged discrimination:

24.4.1 Investigate promptly and

thoroughly;

24.4.2 Consider referral to the SRA if conduct

issue;

24.4.3 Consider whether Legal Ombudsman has

jurisdiction;

24.4.4 Be aware of Equality and Human Rights Commission

jurisdiction;

24.4.5 Document investigation and findings carefully.

SCHEDULE 1: SOLICITOR COMPLAINT FORM

Please complete this form fully. Incomplete forms may delay investigation.

Section A: Your Details

Solicitor Name: _____________________________________________

SRA ID: _____________________________________________

Firm Name: _____________________________________________

SRA Firm Reference: _____________________________________________

Contact Email: _____________________________________________

Contact Phone: _____________________________________________

Date: _____________________________________________

Section B: Buyer Details

Buyer Name (as known): _____________________________________________

Buyer Platform Username/Reference: _____________________________________________

Date(s) of Contact with Buyer: _____________________________________________

Matter Type (if applicable): _____________________________________________

Consumer or Business Client: ☐ Consumer ☐ Business ☐ Unknown

Section C: Complaint Details

Category of Complaint (tick all that apply):

☐ Fraudulent or dishonest conduct

☐ Money laundering / financial crime concerns

☐ Abusive, threatening or harassing behaviour

☐ Non-payment / payment fraud

☐ Breach of Platform terms

☐ Discriminatory behaviour

☐ Other serious conduct (please specify)

Severity Assessment (tick one):

☐ CRITICAL - Immediate risk (threats, ongoing crime)

☐ HIGH - Criminal/regulatory concerns

☐ MEDIUM - Serious misconduct

☐ STANDARD - Policy breach

☐ LOW - General concern

Section D: Description of Complaint

Please provide a detailed description of the complaint:

(Continue on separate sheet if necessary)

Section E: Supporting Evidence

Please list all evidence attached:

☐ Communications (emails, messages, letters) - Number: ___

☐ Platform message screenshots - Number: ___

☐ Documents provided by buyer - Number: ___

☐ Evidence of falsified documents

☐ Telephone notes/recordings

☐ Other evidence: ___

Section F: AML/Financial Crime (if applicable)

Have you filed a SAR with the NCA?

☐ Yes - SAR filed (do NOT provide SAR reference or details)

☐ No - SAR not required

☐ Considering - decision pending

Section G: Vulnerable Client Consideration

Do you believe the buyer may be vulnerable?

☐ Yes (please describe concerns)

☐ No

☐ Unsure

Section H: Declaration

I confirm that:

☐ The information provided is true and accurate

☐ I understand this complaint will be investigated

☐ I consent to my details being shared as necessary

☐ I have fulfilled any regulatory obligations (e.g., SAR filing)

Signature: _____________________________________________

Date: _____________________________________________

SCHEDULE 3: SRA COMPLAINTS HANDLING REQUIREMENTS

SRA Code of Conduct for Firms - Rule 7

You ensure that a written procedure is in place for handling complaints, that this is brought to clients' attention at the time of engagement, and that complaints are dealt with promptly, fairly and free of charge.

SRA Transparency Rules

For certain services, complaints information must be published on your website including:

Your complaints procedure

How to make a complaint

Your right to complain to the Legal Ombudsman

Any right to complain to the SRA

Any other complaints body

Client Care Requirements

Your client care letter must include:

Your complaints procedure

Right to complain to the Legal Ombudsman

Time limits for complaining (1 year from act, 6 months from final response)

Contact details for the Legal Ombudsman

COLP Responsibilities

The COLP must:

Take all reasonable steps to ensure compliance with SRA requirements

Record any failure to comply and make appropriate records

Report material failures to the SRA promptly

Reporting to SRA

You must report to the SRA:

Serious financial difficulty that might put clients at risk

Action by another regulator or authority

Any indictment, charge or conviction of a solicitor

A finding by the Legal Ombudsman of discrimination

A finding by the Legal Ombudsman of failure to pay compensation

SCHEDULE 4: LEGAL OMBUDSMAN INFORMATION

Contact Details

Legal Ombudsman

PO Box 6167, Slough SL1 0EH

Website: www.legalombudsman.org.uk

Email: enquiries@legalombudsman.org.uk

Phone: 0300 555 0333

Time Limits (Updated)

  • The time limits were updated. Complaints must be made to the Legal Ombudsman:

Within 1 YEAR of the act/omission complained about (or 1 year from when you should have known)

Within 6 YEARS of the act/omission

Within 6 MONTHS of the solicitor's final response

What the Legal Ombudsman Needs

You must complain to the solicitor first

The solicitor must have had 8 weeks to respond OR issued final response

Your complaint must be about 'legal services'

The complaint must be within time limits

What the Legal Ombudsman Can Award

Compensation up to £50,000

Refund of fees

Direction to put things right

Apology

What the Legal Ombudsman Cannot Do

Investigate conduct issues (SRA's role)

Strike off solicitors

Award unlimited damages

Handle commercial disputes

SCHEDULE 5: REGULATORY REPORTING TRIGGERS

Report to National Crime Agency (SAR)

You MUST report if you know or suspect money laundering:

Unexplained wealth

Complex/unusual transactions with no apparent purpose

Inconsistent information from client

Client reluctant to provide verification

Funds from high-risk jurisdictions

Cash transactions (unusual for the transaction type)

Third-party funding without explanation (LSAG 2025)

Beneficial ownership concealment (>25% threshold)

Sanctions matches or concerns

  • DO NOT TIP OFF: It is a criminal offence to disclose that a SAR has been or will be made if this might prejudice an investigation.

Report to OFSI (Sanctions)

Match or potential match on sanctions lists

Suspected sanctions evasion

Transactions involving sanctioned countries

Fatf​

Black List

connections (DPRK, Iran, Myanmar)

Report to Police

Immediate threats of violence

Ongoing criminal activity

Fraud in progress

Other serious criminal conduct

Report to SRA

Serious misconduct by solicitors

Concerns about another firm

Matters affecting client protection

Required reports under SRA rules

Report to ICO

Data breaches likely to result in risk to individuals

Within 72 hours of becoming aware

Report to FCA (if applicable)

Breaches of FCA rules

Required regulatory reports

Suspicious activity in regulated activities

Schedule 6: Consumer Protection Checklist​

ℹ Use this checklist when complaints involve consumer clients.

Consumer Rights Act 2015

☐ Was client a consumer (individual outside trade/business)?

☐ Were services performed with reasonable care and skill?

☐ Were services completed in agreed timescale?

☐ Was price reasonable (if not agreed)?

☐ Are there any unfair terms in the contract?

☐ Has consumer exercised right to repeat performance?

☐ Has consumer exercised right to price reduction?

Consumer Contracts Regulations 2013

☐ Was pre-contract information provided?

☐ Was 14-day cancellation right explained?

☐ Was model cancellation form provided?

☐ Did consumer exercise cancellation right?

☐ Was confirmation provided on durable medium?

Digital Markets, Competition and Consumers Act 2024

☐ Were all mandatory costs disclosed upfront?

☐ Was there any drip pricing (fees added later)?

☐ Was total price clearly stated at outset?

☐ Were there any hidden charges?

Vulnerability Assessment

☐ Is the complainant potentially vulnerable?

☐ What vulnerability factors are present?

☐ Have reasonable adjustments been made?

☐ Is additional support needed?

Document Information​

This Complaints Process document is issued by [Platform Name] and forms part of the Solicitor Terms and Conditions.

Document Version: 1.0

Effective Date: January 2026

Last Reviewed: January 2026

Next Review: January 2026

─────────────────────────────────────

Regulatory Framework

SRA Standards and Regulations 2019 (as amended 2025)

SRA Code of Conduct for Solicitors, RELs, RFLs

SRA Code of Conduct for Firms (Rule 7)

SRA Transparency Rules 2018 (as amended)

Money Laundering Regulations 2017 (as amended)

LSAG Anti-Money Laundering Guidance 2025

Proceeds of Crime Act 2002

Terrorism Act 2000

Sanctions and Anti-Money Laundering Act 2018

Economic Crime and Corporate Transparency Act 2023

Consumer Rights Act 2015

Consumer Contracts Regulations 2013

Digital Markets, Competition and Consumers Act 2024

Equality Act 2010

UK GDPR and Data Protection Act 2018

Related Documents

Solicitor Terms and Conditions V1.0

Buyer Terms and Conditions V1.0

Platform Privacy Notice

AML/KYC Compliance Verification Guide V1.0

Solicitor Compliance Audit Checklist V1.0

─────────────────────────────────────

[Platform Name]

Operated by: [Company Name]

Company registration number: [X]

Registered address: [Address]

Complaints

email:

solicitor-complaints@[platform].com

Emergency line: [Phone Number]