- Publication Date
- 2024-04-26
The SRA commissioned a forensic investigation into the law firm in January 2023. The investigation identified several issues with the firm’s AML policies, as well as a failure to obtain two accountant’s reports at the end of the financial years 2021 and 2022. The forensic investigation also identified issues with the firm’s regular client account reconciliations.
It was found that:
Between June 2017 and April 2019, the firm failed to have in place an adequate AML firm-wide risk assessment (FWRA) pursuant to applicable regulations.
Between March 2021 and January 2024, the firm again failed to have in place an adequate FWRA pursuant to applicable regulations.
Between June 2017 and April 2019, the firm failed to establish and maintain AML policies, controls, and procedures (PCPs) required by regulations.
Between January 2020 and January 2024, the firm failed to establish and maintain AML policies, controls, and procedures as required.
For the accounting periods ending July 2021 and July 2022, the firm failed to obtain accountant’s reports for those accounting periods within six months.
Between September 2021 and November 2022, the firm failed to investigate and resolve differences shown by its client account reconciliation.
The firm was directed to pay a financial penalty of £6,663. This decision was influenced by the serious nature of the firm's conduct, including breaches of the regulations designed to prevent money laundering and improper withdrawals of client money, as well as prolonged negligence in fulfilling regulatory obligations.
Mitigating factors included that the firm was compliant with FWRA and PCPs between April 2019 and 2020/2021, had partially remedied the breaches by updating policies and obtaining accountants’ reports, and showed some insight and made admissions.