Conveyancing firms pass SRA source of funds audits on substance but fail on documentation. The same gap appears in desktop review after desktop review: not incorrect analysis, but missing written records of the decision-making process that led a fee earner to accept or escalate a transaction. Two compliance consultants now claim a card-based training game can close that gap where technology and conventional CPD have not.
Tom Lyes, formerly director at source of funds technology provider Armalytix and now running Tom Lyes Consultancy, has partnered with Steve Brett of E3 Compliance Training to launch a facilitated game designed to train conveyancers to document their source of funds thinking in real time. The product targets what the creators describe as a recurring pattern in SRA audits: fee earners who reach the right compliance conclusion mentally but create no usable audit trail for supervisors or regulators.
"When I speak to AML consultants or compliance heads, the fee earner rarely gets the analysis wrong," Lyes said. "What's happening in practice is the explanation and storytelling is the real gap. That's what this game trains for."
The claim rests on anecdotal conversations rather than published SRA enforcement data. The regulator has not released granular thematic findings on source of funds documentation quality in recent AML supervision reports, though desktop audits expanded significantly after 2019 and have become a routine feature of SRA risk-based supervision.
A behavioural problem with a process solution
Source of funds verification is required under the Proceeds of Crime Act 2002 and Money Laundering Regulations 2017. The SRA's AML guidance and Accounts Rules make clear that firms must not only conduct the analysis but retain adequate evidence of it. Desktop audits examine client files for that evidence, and failures can result in warning letters, conditions on practising certificates, or referral to the Solicitors Disciplinary Tribunal in serious cases.
The game involves paired play over 60 to 90 minutes, with a facilitator present. One player documents a source of funds decision based on a scenario card whilst the other evaluates the written record. They then switch roles. The claimed benefit is immediate peer feedback on documentation quality, exposing the gap between internal reasoning and what actually appears on file.
"We need people to engage with the challenge of documenting their thinking on source of funds and develop habits to reduce the friction," Brett said. "By helping people see the gap between their thought process and what they document together with tools to reduce the friction, we help people gain the skills and habits to quickly create short and effective documentation."
The product is positioned as a skills-building intervention rather than a technology solution. That distinction matters for compliance heads evaluating ROI. Traditional CPD delivers knowledge but rarely changes daily habits. Case management systems can enforce documentation through mandatory fields and workflow gates, but only if firms configure them properly and fee earners don't route around the controls. A facilitated training session sits between those two approaches, aiming to build muscle memory without requiring software integration.
What's missing from the evidence base
The creators claim 10 years of development, though it is unclear whether that refers to the game itself or their accumulated professional experience in AML compliance. No pilot results, client testimonials, or before-and-after file quality metrics have been published. There is no comparison to alternative interventions such as post-transaction file reviews with individual feedback, standardised templates embedded in matter management systems, or simple checklists tied to billing milestones.
Lyes' background is instructive. Armalytix provided technology to automate aspects of source of funds verification. A pivot to training could indicate that software alone does not solve the documentation gap, or it may reflect a complementary revenue model targeting a different part of the compliance budget. Either way, the move suggests that even purpose-built technology has not eliminated the behaviour the game now claims to address.
Compliance officers considering the product will need to ask what enforcement risk the documentation gap actually carries. If SRA audits "routinely" flag missing source of funds records, how often does that finding escalate beyond an informal warning? What share of fines, conditions, or referrals to the SDT stem from inadequate documentation versus substantive failures to verify or report suspicious activity? The creators have not provided that breakdown, and the SRA does not publish it in granular form.