Between June 2017 and October 2023, the law firm failed to have in place, in terms of the firm’s overall anti-money laundering (AML) controls, a comprehensive firm-wide risk assessment and fully compliant policies, controls, and procedures as required by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
The relevant lawyer at the firm provided the Solicitors Regulation Authority (SRA) with inaccurate information in October 2020 by declaring compliance with the required firm-wide risk assessment when in fact, no such assessment was in place.
Between November 2022 and February 2023, the law firm failed to conduct adequate source of funds checks and client/matter risk assessments as required by the Money Laundering Regulations.
The SRA's audit led to a decision to impose a financial penalty on the law firm due to serious breaches of legal and regulatory obligations over more than six years. Despite recent remedial actions, the firm’s misconduct persisted beyond reasonable time frames.