Mixed Funds
Mixed funds arise when client money and office money are held together in a single bank account in breach of the SRA Accounts Rules 2019. Mixed funds are an AML concern because they can mask the source of payments leaving the firm and create reconciliation gaps — both of which can support a money laundering case if proceeds of crime are involved.
detection often starts with a five-weekly client account reconciliation. A firm with persistent mixed-funds incidents will trigger SRA scrutiny on both accounts compliance and AML controls — the two regulators expect each other's standards to be met.
How different roles use Mixed Funds
A good definition should change the next action for the person reading it.
Partner or director
Check whether this term affects acceptance risk, fee scope, supervision exposure, or sign-off responsibility.
ContinueMLRO or compliance lead
Map the term to evidence, escalation, monitoring, training, and inspection readiness.
ContinueClient-facing team member
Use the plain-English explanation to ask better client questions and write clearer file notes.
ContinueOther terms that go with Mixed Funds
A client account is a separately designated bank account, regulated under the SRA Accounts Rules 2019, in which a law firm holds money received from or for a client. Client account funds must be kept distinct from the firm's office funds, must be paid out only for the purpose for which they were received, and must be reconciled at least every five weeks. Misuse of client account funds is an SRA disciplinary offence and a frequent vector for money laundering through legal practice.
The Solicitors Regulation Authority is the independent regulator of solicitors and law firms in England and Wales. It is the supervisory authority under MLR 2017 for SRA-regulated firms — issuing AML guidance, conducting thematic and on-site reviews, and imposing fines, conditions, or strike-offs for failures. SRA fines for individual AML breaches can reach £25,000; firm-level fines can exceed £250m for traditional firms (lower caps apply to alternative business structures).
Before you treat Mixed Funds as handled
- Confirm which regulation, policy, or internal procedure the term maps to.
- Document the decision or evidence trail in the client file, not only in email or chat.
- Escalate where the term indicates higher risk, sanctions exposure, PEP status, suspicion, or missing evidence.
- Keep the wording consistent across onboarding, review notes, training material, and inspection packs.
Put Mixed Funds into practice with Certivus
Knowing the term is the first step. Certivus gives you the workflows — client intake, CDD, EDD, PEP and sanctions screening, audit-ready records — to apply it across every client.
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