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The SRA approach is not a gentle nudge with words of advice, investigations focus on suspected breaches of the Code of Conduct.

Under the same Code of Conduct you have a duty to be open, transparent and co-operative with the SRA. Since COLP's and COFA's were introduced the SRA have an easy target to pursue if things are not perfect.

Defending solicitors and firms engaging with the SRA and appearing before the SDT tells me firms need to respond carefully, sticking the facts and if they are not sure should get advice.

If the SRA do not understand your firms approach they will find fault with it, if you explain it correctly (with evidence) the risks reduce.

The issue is not proving your innocence as suggested by another commentator below (anonymous 01:18) it is show your compliance approach is working. COLP's in particular on this issue need to demonstrate the systems are right and COFA's need to show the financial transactions are compliant. Compliance not "innocence" is a subtle difference but an important one.

In fairness to the SRA they investigate lots of things that do not end in disciplinary action because of the distinction.

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