Introduction
The Solicitors Regulation Authority (SRA) stands at a historic crossroads, as does the broader financial services sector. The International Monetary Fund has described the arrival of tokenisation as “a fundamental reconfiguration of the financial system”, and the Bank of England’s Stablecoin Consultation is monitoring the emergence of self-custody for digital wallets as an alternative to traditional financial intermediation. SRA Accounts Rules have served as the bedrock of client protection in England and Wales for over 100 years. Those rules presuppose that solicitors hold client money in segregated bank accounts, record movements through ledger entries and maintain entitlements payable on demand. That model worked when money meant sterling balances at regulated banks. The world of tokenisation makes this model progressively harder to apply.
Client money is sacrosanct
The SRA has signalled a clear direction of travel from passive to proactive compliance. Firms must demonstr…


