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Anti-Money Laundering Requirements for Estate Planning Practices: A Compliance Framework for the FCA Transition Era

· 21 min

Executive Summary

Estate planning practices face an unprecedented AML compliance transformation as the United Kingdom prepares for the most significant supervisory restructuring in the regime's history. The October 2025 government announcement confirming the Financial Conduct Authority as the single professional services supervisor fundamentally alters the regulatory architecture for solicitors conducting will-writing, trust creation, and estate administration.1 The SRA's 2024-25 AML Annual Report reveals concerning compliance deficits across the profession: 32.4% of inspected firms were non-compliant, 16% of files lacked client and matter risk assessments, and 41% required feedback on source-of-funds controls.2 Meanwhile, the April 2025 LSAG guidance introduces enhanced beneficial ownership verification requirements that demand significant operational adjustments.3 This article provides a comprehensive compliance framework for private client practitioners navigating the transition period, addressing the specific AML risks inherent in estate planning work and the practical implications of dual regulation by the FCA and existing legal regulators.

1. The Regulatory Landscape Transformation

FCA as Single Supervisor

The October 2025 government announcement represents the most fundamental restructuring of anti-money laundering supervision for the legal profession since the Money Laundering Regulations first applied to solicitors. The Financial Conduct Authority's designation as the single professional services supervisor eliminates the existing framework of 25 Professional Body Supervisors and consolidates AML oversight under a single, financially-focused regulator with substantial enforcement experience.1

This decision followed extensive consultation and rejected the SRA's bid to assume expanded supervisory responsibilities across the entire legal sector. The rationale centres on consistency of supervision, the FCA's existing expertise in financial crime prevention, and the perceived benefits of a single regulatory approach across all professional services sectors engaged in activities creating money laundering risk.4

The HM Treasury consultation published in December 2025 outlines the FCA's proposed powers, which extend significantly beyond current Professional Body Supervisor capabilities. These include early intervention directions requiring or prohibiting specific actions, the power to require firms to appoint skilled persons for compliance reviews, the ability to enter and inspect premises without warrant, criminal prosecution powers for Money Laundering Regulations breaches, and a comprehensive toolkit of civil penalties, suspensions, prohibitions, and public censures.5

Dual Regulation Architecture

The transition creates an unprecedented dual regulation model for solicitors. The FCA will assume responsibility for AML supervision while the SRA retains authority over professional conduct, competence, and the broader regulatory framework under the Legal Services Act 2007. This bifurcation requires practices to develop integrated compliance frameworks capable of satisfying two distinct regulatory bodies with potentially different priorities and approaches.

The Economic Crime and Corporate Transparency Act 2023 reinforces this architecture by establishing a new regulatory objective of promoting the prevention and detection of economic crime, now embedded within the Legal Services Act 2007.6 The removal of the statutory cap on SRA financial penalties for economic crime breaches signals Parliament's intent that professional regulators maintain meaningful enforcement capability even as AML-specific supervision transfers to the FCA.

Timeline Uncertainties

While the government has confirmed the FCA's role, the precise transition timeline remains subject to primary legislation and the development of detailed implementation frameworks. Practices face a challenging planning environment: the direction of travel is clear, but the specific compliance date and operational requirements await final confirmation through enacted legislation and FCA handbook amendments.

This uncertainty should not, however, delay compliance preparation. The SRA's current enforcement data demonstrates that practices failing to achieve compliance under existing supervision are unlikely to fare better under a regulator with more extensive powers and a financial services enforcement culture. The transition period represents a critical window for remediation.

2. Estate Planning AML Risk Profile

The Compliance Gap Paradox

Private client work presents a paradox that the SRA's 2024-25 enforcement data illuminates: estate planning services are frequently categorised as lower risk within firm-wide assessments, yet the activities involved create sophisticated money laundering vulnerabilities that merit enhanced scrutiny. The Law Society's guidance on trust and company service provision explicitly identifies private client services as attractive vehicles for money laundering, encompassing estate administration, trust creation and management, company and charity formation, tax advice, and client account handling.7

This risk, according to the Law Society, is sometimes underestimated by private client practitioners, particularly in high street firms dealing predominantly with local and longstanding clients. The familiarity that characterises many private client relationships can inadvertently lower vigilance precisely where criminals may seek to exploit professional service providers' involvement to legitimise transactions.7

The FATF's guidance for legal professionals reinforces this concern, noting that criminals seek legal professional involvement specifically for transaction completion and the appearance of legitimacy that professional engagement confers.8 Estate planning work, with its involvement in wealth structuring, trust formation, and asset transfers, sits squarely within this risk profile.

LSAG Trust and Will Typologies

The Legal Sector Affinity Group guidance provides specific typologies relevant to estate planning work. Typology 11 addresses trusts and standard form wills, while Typology 12 covers trusts and advice upon a will.3 These typologies identify red flags and risk indicators specific to private client activities that should inform client and matter risk assessments.

Practitioners should note that trust creation presents particular vulnerabilities. The ability to structure assets across generations, create discretionary interests, and establish offshore or complex multi-jurisdictional arrangements provides mechanisms that can be exploited for illicit purposes. The extended timeframes involved in estate planning work and the emotional context of family wealth arrangements can also reduce client willingness to provide full transparency regarding the origins and nature of assets.

Red flags identified by the LSAG typologies for trust and will work include instructions to establish trusts with no apparent legitimate purpose, requests for unusually complex trust structures disproportionate to the estate's value, beneficiaries located in high-risk jurisdictions with no clear connection to the settlor, and last-minute changes to will provisions that redirect significant assets to previously unknown parties. The guidance also highlights scenarios where clients resist providing source of wealth information for assets being settled into trust, or where the stated purpose of a trust arrangement is inconsistent with the client's overall financial profile.3

Estate Administration Due Diligence

Estate administration creates distinct due diligence obligations that differ from transactional work. The Law Society's guidance requires practitioners to develop a broad understanding of how the deceased accumulated wealth, with further enquiries where unusual estate features exist.9 This obligation extends beyond simple identity verification to encompass meaningful assessment of the estate's legitimacy.

Practitioners must conduct appropriate due diligence on the deceased, executors, and beneficiaries. The will trust registration exemption, which permits exclusion from Trust Registration Service requirements for two years from the date of death, does not diminish the substantive AML obligations that apply throughout estate administration.9 Rather, the registration exemption acknowledges practical timing considerations without relaxing the underlying compliance requirements.

Source of Wealth and Source of Funds

The distinction between source of wealth and source of funds requires careful application in estate planning contexts. Source of funds concerns the origin of monies or assets involved in a specific transaction, while source of wealth addresses the broader question of how a client has accumulated their overall wealth and assets.

Estate administration frequently involves assets accumulated over decades, potentially across multiple jurisdictions and through various mechanisms. Practitioners cannot simply accept that assets held at death were legitimately acquired; the due diligence obligation requires proportionate enquiry based on risk assessment. Where clients or estates present enhanced risk indicators, more detailed enquiry into wealth origins becomes necessary.

3. The April 2025 LSAG Guidance Impact

Enhanced Regulation 28(3A) Requirements

The Legal Sector Affinity Group guidance effective from 23 April 2025, approved by HM Treasury, introduces significant changes to beneficial ownership verification requirements under Regulation 28(3A) of the Money Laundering Regulations 2017.3 The enhanced requirements move beyond simple identification of beneficial owners to require that firms take reasonable measures to understand the ownership and control structure of legal persons, trusts, companies, foundations, or similar arrangements.

In practical terms, this may require requesting and reviewing company charts, shareholder registers, trust documentation including offshore trust deeds, and other materials necessary to comprehend how ownership and control are actually exercised within relevant structures. The obligation is explicitly risk-based, proportionate, and subject to an effectiveness standard: measures must actually achieve understanding of the relevant structures rather than merely document a process.10

For estate planning practitioners, this has immediate implications for trust work, estate administration involving corporate assets or complex structures, and any matter touching international arrangements. The guidance moves compliance from a checklist approach toward substantive engagement with the structures being employed.

Beneficial Ownership Threshold Clarification

The April 2025 guidance corrects an ambiguity regarding the beneficial ownership threshold, clarifying that the relevant test is ownership of more than 25% rather than 25% or more.3 While this distinction may appear technical, it eliminates potential compliance uncertainty for practitioners assessing complex ownership structures at the margin.

Third-Party Funding Scrutiny

The guidance introduces enhanced scrutiny requirements where someone other than the client pays for or contributes to transactions. This scenario arises regularly in estate planning contexts: family contributions to property purchases, third-party funding of trust establishment costs, or arrangements where estate expenses are met from sources other than the estate itself.

Practitioners should ensure client and matter risk assessment frameworks explicitly address third-party funding scenarios and that appropriate enquiries are documented regarding the source and legitimacy of funds from persons other than the primary client.

High-Risk Third Country Dynamics

The April 2025 guidance references FATF call for action countries rather than the Schedule 3ZA list previously employed. The February 2025 redesignation of Lao PDR as a high-risk jurisdiction demonstrates the dynamic nature of country risk and the need for practices to maintain current awareness of FATF determinations.3

Estate planning work frequently involves international elements: beneficiaries resident overseas, assets held in foreign jurisdictions, or clients with historical connections to countries that may present enhanced risk. Compliance frameworks must accommodate these international dimensions while maintaining proportionality.

4. Compliance Gap Analysis

SRA 2024-25 Enforcement Findings

The SRA's Anti-Money Laundering Annual Report for 2024-25 provides the most comprehensive picture of compliance performance across the profession.2 The statistics reveal systemic weaknesses that the incoming FCA supervision will encounter: 32.4% of inspected firms were deemed non-compliant with AML requirements, with an additional 54% only partially compliant. The 5,873 files reviewed identified significant deficiencies across core compliance obligations.11

The scale of SRA supervision, encompassing 5,569 firms representing approximately two-thirds of the 9,149 authorised firms conducting regulated activities, provides statistically meaningful insight into profession-wide compliance performance.2

Common Failure Patterns

Analysis of the 426 AML reports received by the SRA in 2024-25, nearly double the 227 received in 2023-24, reveals consistent failure patterns.2 The most common referral reasons were:

Failure to perform risk assessment on client and matter represented the leading deficiency, appearing in 162 reports. This fundamental obligation under the Money Laundering Regulations requires assessment of both the client and the specific matter to determine appropriate due diligence levels. The failure rate suggests that many firms either lack systematic assessment processes or apply them inconsistently across matters.

Failure to carry out source of funds checks appeared in 101 reports, with 10% of files reviewed showing no evidence whatsoever of source of funds enquiry. A further 41% of files required feedback on source-of-funds controls, indicating partial or inadequate implementation.2 Given the centrality of source of funds enquiry to AML compliance, these statistics indicate a fundamental practice deficiency.

Failure to have adequate or effective policies, controls and procedures appeared in 99 reports, while failure to have a firm-wide risk assessment featured in 65 reports. These failures represent foundational compliance infrastructure deficits that undermine all downstream obligations.

Private Client Specific Vulnerabilities

While the SRA does not separately report private client compliance statistics, the overall deficiency patterns apply with particular force to estate planning work. The extended relationship timeframes typical of private client practice may lead to reduced formality in documentation. The trust inherent in longstanding client relationships can reduce scrutiny. The complexity of trust and estate structures may exceed the risk assessment capabilities of firms without specialised frameworks.

The 73% concentration of SARs submitted by the SRA involving conveyancing-related instructions suggests that estate planning work receives proportionally less suspicious activity reporting attention.212 This may reflect lower intrinsic risk, but alternatively may indicate under-identification of suspicious activity in private client matters. Practices should ensure that SAR consideration is embedded within estate planning workflows to the same degree as conveyancing work.

5. The MLRO Function Under FCA Supervision

Strategic Elevation

The Money Laundering Reporting Officer function assumes heightened strategic importance under FCA supervision. The FCA's proposed powers, including early intervention directions and skilled person requirements, create direct regulatory engagement with MLRO effectiveness that exceeds current Professional Body Supervisor practice.5 MLROs should anticipate more intensive regulatory interaction and greater personal exposure to enforcement consequences.

The role requires repositioning from a compliance monitoring function to a strategic risk management position with board-level visibility and authority. Practices should ensure that MLRO appointment reflects appropriate seniority, that the individual has genuine authority to escalate concerns and require remediation, and that governance structures support effective discharge of the role.

SAR Submission Obligations

Section 330 of the Proceeds of Crime Act 2002 establishes the criminal offence of failure to disclose knowledge or suspicion of money laundering where information is obtained in the course of regulated sector business.13 The maximum penalty of five years imprisonment underscores the personal criminal exposure that MLROs and other regulated sector professionals face.

The legal professional privilege defence protects communications made in privileged circumstances, but this protection does not extend to communications furthering a criminal purpose.13 MLROs should ensure that SAR decisions properly assess privilege boundaries and that legal advice is sought where appropriate before concluding that privilege prevents disclosure.

The SRA submitted 19 SARs to the National Crime Agency in 2024-25 involving over GBP 148 million in suspected criminal proceeds, an increase from 14 SARs in 2023-24.214 The UK Financial Intelligence Unit received over 860,000 SARs in 2024-25, placing the UK among the busiest financial intelligence units globally.1516 This volume reflects the reporting burden across all regulated sectors, but also indicates the scale of activity that the FCA's supervision will need to address.

Governance and Board Reporting

FCA supervision will likely introduce enhanced governance expectations regarding board awareness of AML risks and compliance performance. While the precise requirements await final regulatory guidance, practices should establish formal reporting mechanisms that ensure appropriate oversight bodies receive regular AML compliance reporting, are informed of significant incidents or concerns, and maintain awareness of the practice's risk profile.

The failure to prevent fraud offence under the Economic Crime and Corporate Transparency Act 2023, effective from 1 September 2025, applies to large organisations and creates senior management exposure for fraud committed by employees or agents for the organisation's benefit.6 While focused on fraud rather than money laundering specifically, this development reinforces the broader trend toward enhanced senior accountability for economic crime prevention.

6. Practical Implementation Framework

Compliance Remediation Priorities

Practices should prioritise remediation of the common failure patterns identified in SRA enforcement data. A structured approach would address:

Firm-wide risk assessment requires annual review and should explicitly address estate planning work within the broader practice risk profile. The assessment should identify higher-risk activity types, client categories, geographic exposures, and delivery channel vulnerabilities specific to private client work.

Client and matter risk assessment processes require systematic application to every engagement within the Money Laundering Regulations scope. Practices should implement documented workflows that require completion of risk assessment before substantive work commences, with escalation mechanisms for enhanced risk matters.

Source of funds and source of wealth enquiry should be embedded within client onboarding processes with clear documentation requirements. For estate administration, this includes enquiry regarding the deceased's wealth accumulation and any unusual features of the estate.

Policies, controls, and procedures should be reviewed against LSAG guidance and updated to reflect the April 2025 requirements. Documentation should demonstrate that policies are current, comprehensive, and effectively implemented.

Compliance Checklist for the FCA Transition

To assist practices in structuring their remediation programmes, the following checklist summarises priority actions aligned to the most common SRA enforcement findings:

Governance: confirm MLRO appointment at appropriate seniority; establish board-level AML reporting schedule; document MLRO authority and escalation procedures; review terms of reference for compliance committee or equivalent oversight body.

Risk assessment: complete or update firm-wide risk assessment addressing estate planning activities specifically; implement systematic client and matter risk assessment for all regulated engagements; document risk assessment methodology and calibration criteria; establish enhanced due diligence triggers aligned to LSAG typologies 11 and 12.

Due diligence: embed source of funds and source of wealth enquiry within onboarding workflows; implement Regulation 28(3A) ownership structure verification procedures; document third-party funding assessment protocols; establish procedures for estate administration due diligence on deceased, executors, and beneficiaries.

Training and awareness: deliver role-specific AML training addressing private client typologies; document training completion with content summaries and assessment results; schedule annual refresher training with updates reflecting regulatory developments.

Trust Registration Service Compliance

The Trust Registration Service obligations continue to evolve, with proposed 2026 changes expanding scope while introducing new exemptions relevant to estate administration.17 Will trusts remain exempt from registration for two years from the date of death, providing a compliance window during estate administration. Section 34 Trustee Act 1925 trusts will be similarly exempted for two years following trustee death, and deed of variation trusts created during estate administration will receive equivalent treatment.

Practices should maintain awareness of registration deadlines and ensure that trust registration is completed within required timeframes for trusts falling within scope. The maximum GBP 5,000 penalty for registration failure provides meaningful financial exposure, particularly if multiple registration failures occur across a practice's trust portfolio.

Documentation and Record-Keeping

The transition to FCA supervision heightens the importance of comprehensive documentation demonstrating compliance with all AML obligations. Practices should ensure that:

All risk assessments are documented contemporaneously with sufficient detail to demonstrate the reasoning applied. Enhanced due diligence measures for higher-risk matters should be specifically documented.

Source of funds and source of wealth enquiries should be recorded with supporting documentation retained. Where clients decline to provide requested information, the firm's decision whether to proceed and the rationale should be documented.

Training completion should be recorded at individual level with evidence of content and assessment. Annual refresher training should be documented alongside initial onboarding training.

SAR consideration should be documented even where no SAR is submitted, demonstrating that the obligation was addressed and the conclusion reached.

Staff Training Requirements

AML training obligations extend to all relevant employees, with content calibrated to role and risk exposure. Private client practitioners require training addressing the specific typologies and risk indicators relevant to estate planning work, not merely generic AML awareness content.

Training should address the Regulation 28(3A) enhanced verification requirements, source of funds and source of wealth enquiry, recognition of red flags specific to trust and estate work, and the SAR submission process including legal professional privilege boundaries. Practices should document training delivery and consider knowledge assessment mechanisms to verify understanding.

Conclusion

The transition to FCA supervision represents the most significant AML compliance challenge for estate planning practices in the regime's history. The combination of a more powerful supervisor, enhanced LSAG guidance requirements, and concerning SRA enforcement data creates an imperative for immediate compliance attention.

Private client practitioners occupy a particularly complex position: the traditional characterisation of estate planning as lower-risk work conflicts with the sophisticated money laundering vulnerabilities that trusts, wealth structuring, and estate administration actually present. The compliance gap paradox, where perceived lower risk leads to reduced vigilance in an area meriting enhanced attention, must be addressed through explicit risk assessment frameworks that properly categorise private client activities.

The dual regulation model requires practices to develop integrated compliance approaches satisfying both FCA AML requirements and continuing SRA professional conduct obligations. The narrow window before FCA supervision commences should be utilised for systematic compliance remediation, particularly addressing the client and matter risk assessment, source of funds enquiry, and policy documentation deficiencies that SRA enforcement data identifies as profession-wide weaknesses.

This AML compliance transformation occurs within a broader legislative reform environment affecting estate planning practice. The Law Commission's Modernising Wills report and draft Bill for a new Wills Act, published in May 2025, proposes provisions for electronic wills created through reliable systems with remote witnessing capabilities.18 The government welcomed the Law Commission's recommendations in May 2025, though primary legislation has not yet been introduced. These prospective reforms carry AML implications: digital will creation platforms and remote witnessing procedures will introduce new identity verification challenges and potential risk vectors that AML compliance frameworks must anticipate. Practices preparing for FCA supervision should factor the broader wills modernisation agenda into their forward compliance planning.

Practices that achieve compliance excellence during this transition period will be positioned advantageously as FCA supervision commences. Those that fail to remediate identified deficiencies will encounter a supervisor with more extensive powers and a demonstrated willingness to deploy them.

CPD Declaration

Estimated Reading Time: 20 minutes Technical Level: Advanced Practice Areas: Anti-money laundering compliance, Private client practice, Risk management, Professional regulation

Learning Objectives

Upon completing this article, practitioners will be able to:

  1. Identify the three most common compliance failures detected in SRA AML inspections and their relevance to estate planning work
  2. Explain the enhanced beneficial ownership verification requirements under Regulation 28(3A) following the April 2025 LSAG guidance
  3. Apply a risk-based client and matter assessment framework to estate administration and trust creation work
  4. Evaluate the implications of FCA supervision for MLRO responsibilities and practice governance structures
  5. Distinguish between source of funds and source of wealth obligations in private client due diligence contexts

SRA Competency Mapping

  • A1: Ethics, professionalism and judgement (AML compliance as professional obligation)
  • A2: Technical legal practice (Money Laundering Regulations application)
  • A3: Managing yourself and your own work (personal compliance responsibilities)
  • B6: Risk and compliance (firm-wide AML framework implementation)

Reflective Questions

  1. How would you revise your practice's client and matter risk assessment framework to address the enhanced Regulation 28(3A) ownership structure verification requirements?
  2. What additional source of funds and source of wealth enquiries would be appropriate when administering an estate with international elements or complex trust structures?
  3. How should MLRO reporting and governance arrangements be adapted to prepare for FCA supervision and the associated early intervention powers?

Professional Disclaimer

The information presented reflects the regulatory and legislative position as of 2026-01-28. Regulations, tax rules, and professional guidance are subject to change. Readers should independently verify all information before acting and seek advice from appropriately qualified solicitors, financial advisors, or other professionals for their specific circumstances.

Neither WUHLD nor the author accepts liability for any actions taken or decisions made based on the content of this article. Professional readers are reminded of their own regulatory obligations and duty of care to their clients.

Footnotes

Footnotes

  1. FCA Statement on Government's Decision on AML/CTF Supervision Reform (October 2025). https://www.fca.org.uk/news/statements/governments-decision-reforming-anti-money-laundering-and-counter-terrorism-financing-supervision ↩ ↩2

  2. SRA Anti-Money Laundering Annual Report 2024-25 (October 2025). https://www.sra.org.uk/sra/research-publications/aml-annual-report-2024-25/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  3. SRA LSAG Anti-Money Laundering Guidance (April 2025). https://www.sra.org.uk/solicitors/resources/money-laundering/guidance-support/ ↩ ↩2 ↩3 ↩4 ↩5 ↩6

  4. Legal Futures - FCA to take over anti-money laundering supervision of all lawyers (October 2025). https://www.legalfutures.co.uk/latest-news/fca-to-take-over-anti-money-laundering-supervision-of-all-lawyers ↩

  5. HM Treasury AML/CTF Supervision Reform Consultation (December 2025). https://www.gov.uk/government/consultations/anti-money-laundering-and-counter-terrorist-financing-supervision-reform-duties-powers-and-accountability-consultation ↩ ↩2

  6. Economic Crime and Corporate Transparency Act 2023. https://www.legislation.gov.uk/ukpga/2023/56/enacted ↩ ↩2

  7. Law Society - Anti-Money Laundering Guidance for Trust or Company Service Providers. https://www.lawsociety.org.uk/topics/anti-money-laundering/anti-money-laundering-guidance-trust-or-company-service-providers ↩ ↩2

  8. FATF Guidance for Legal Professionals. https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Rba-legal-professionals.html ↩

  9. Law Society - Trust Registration Service and AML Compliance. https://www.lawsociety.org.uk/topics/anti-money-laundering/trust-registration-service-trs-and-aml-compliance ↩ ↩2

  10. Lexology - The April 2025 LSAG Guidance Updates. https://www.lexology.com/library/detail.aspx?g=81adf0cc-cc3f-4b86-b5b1-be13ca7dc2b2 ↩

  11. Law Society Gazette - AML: One third of inspected firms not compliant, SRA reveals in annual report (2025). https://www.lawgazette.co.uk/news/aml-one-third-of-inspected-firms-not-compliant/5124970.article ↩

  12. Today's Conveyancer - SRA proud of AML progress ahead of FCA handover (2025). https://todaysconveyancer.co.uk/sra-proud-aml-progress-ahead-fca-handover-annual-report-reveals-third-assessed-firms-non-compliant/ ↩

  13. Proceeds of Crime Act 2002, Section 330. https://www.legislation.gov.uk/ukpga/2002/29/section/330 ↩ ↩2

  14. ICLG - Almost a third of law firms failing to comply with AML rules, SRA finds (2025). https://iclg.com/news/23243-almost-a-third-of-law-firms-failing-to-comply-with-aml-rules-sra-finds ↩

  15. NCA SARs Annual Report 2024-25. https://www.nationalcrimeagency.gov.uk/who-we-are/publications/786-sars-annual-report-2025/file ↩

  16. Clifford Chance - NCA Annual Report Highlights Key SAR and DAML Trends (2025). https://www.cliffordchance.com/insights/resources/blogs/regulatory-investigations-financial-crime-insights/2025/04/nca-annual-report-highlights.html ↩

  17. HM Treasury Draft MLR Amendment Regulations 2025 Policy Note. https://www.gov.uk/government/publications/proposed-amendments-to-the-money-laundering-regulations-draft-si-and-policy-note ↩

  18. Law Commission - Modernising Wills: Final Report and Draft Bill (May 2025). https://www.lawcom.gov.uk/project/wills/ ↩