Our framework
gunnercooke is committed to maintaining the highest standards of compliance and risk management. The firm operates a risk-based approach to compliance, identifying and assessing risk across all areas of practice and implementing proportionate controls.
The firm's approach to risk management is built on the principle that compliance is everyone's responsibility — from partners to support staff — and that proactive risk identification is preferable to reactive crisis management.
The Compliance Plan sets out the firm's obligations, the roles responsible for oversight, and the procedures for identifying, escalating, and resolving compliance issues. All partners and consultants are required to read and acknowledge the Compliance Plan at onboarding and whenever a material update is issued.
Who is responsible
COLP
Compliance Officer for Legal Practice
Responsible for ensuring the firm's compliance with its regulatory obligations under the SRA Standards and Regulations. The COLP reports material breaches to the SRA and maintains oversight of the firm's compliance systems and controls.
COFA
Compliance Officer for Finance & Administration
Responsible for ensuring compliance with the SRA Accounts Rules and the firm's financial controls. The COFA oversees client account management and reports material financial breaches to the SRA.
Switzerland escalation: For Swiss matters, escalate compliance questions first to the Swiss Managing Partner, who coordinates with the firm COLP and COFA. Contact details are on the Offices & partners page.
Risk categories
01
Operational risk
Risks arising from inadequate or failed internal processes, people, systems, or external events — including IT failures, human error, and process breakdowns.
02
Strategic risk
Risks arising from adverse business decisions, improper implementation of decisions, or lack of responsiveness to changes in the business environment.
03
Regulatory risk
Risks of legal or regulatory sanctions, financial loss, or reputational damage resulting from failure to comply with laws, regulations, and firm policies.
04
Financial risk
Risks arising from financial loss, including credit risk, liquidity risk, and risks associated with client account management and billing.
All identified risks are recorded in the firm's Risk Register (see Compliance Plan.pdf §3.2.1). The Risk Register is maintained by the COLP and reviewed quarterly. It is not reproduced here — this page summarises the framework; the Register is the system of record.
Our compliance obligations
gunnercooke LLP is subject to the following principal regulatory obligations. This list is drawn from the Compliance Plan §7.7 and is not exhaustive.
- SRA Standards and Regulations (including the Codes of Conduct)
- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017)
- Proceeds of Crime Act 2002 (POCA)
- Terrorism Act 2000
- Bribery Act 2010
- Economic Crime (Transparency and Enforcement) Act 2022
- Economic Crime and Corporate Transparency Act 2023
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- Consumer Protection legislation (where applicable)
- Solicitors Act 1974 (as amended)
- Legal Services Act 2007
In Switzerland, additional obligations apply under the Swiss Anti-Money Laundering Act (GwG), the Swiss Data Protection Act (FADP/revDSG), and the cantonal bar rules. See the Swiss overlay section below.
Reporting a compliance breach
All partners and staff have a duty to report actual or suspected compliance breaches promptly. Early reporting allows the firm to take corrective action before a matter escalates.
A breach includes any failure to comply with a regulatory obligation, the firm's Compliance Plan, SRA rules, or any applicable law. Suspected breaches must be reported even where the reporter is uncertain — it is better to report and investigate than to let a potential issue go unrecorded.
To report a breach: contact the COLP or COFA directly, or in Switzerland, the Swiss Managing Partner. Anonymous reports are accepted per the firm's whistle-blowing policy (Compliance Plan.pdf §24). Do not attempt to resolve a potential breach independently — report first.
Practice-wide risk assessment
The Money Laundering Regulations 2017 require the firm to carry out and document a practice-wide risk assessment (PWRA). The PWRA identifies the money laundering and terrorist financing risks the firm faces and evaluates the adequacy of the firm's policies and controls in addressing those risks.
A Swiss addendum to the PWRA is maintained by the Zurich office. See Compliance status for the latest review date and any outstanding actions.
How this applies in Switzerland
⚠ This section is awaiting confirmation from the Swiss Managing Partner. Do not rely on the contents until this banner is removed.
gunnercooke Switzerland operates under the supervision of the cantonal bar association of the responsible partner's canton. The SRA references throughout the Compliance Plan apply to the UK-regulated entity; Swiss partners operate under equivalent Swiss obligations.
Key Swiss equivalents to UK references in this document:
- MLR 2017 / POCA → Swiss Anti-Money Laundering Act (GwG / LBA)
- UK GDPR / DPA 2018 → Swiss Federal Act on Data Protection (FADP / revDSG, in force September 2023)
- SRA Codes of Conduct → Cantonal bar rules and the Swiss Bar Association (SAV/FSA) professional conduct standards
- COLP/COFA → Swiss Managing Partner coordinates with the firm COLP/COFA for cross-border compliance matters
Where the Swiss regime differs materially from the UK regime, the Swiss position takes precedence for Swiss-seated matters. When in doubt, contact the Swiss Managing Partner or the firm COLP before proceeding.