- Publication Date
- 2024-03-04
The Solicitors Regulation Authority (SRA) conducted an audit and found several instances of misconduct at the law firm by the relevant lawyer. The investigation revealed that the firm's client account was used as a banking facility for two clients from December 2021 to March 2022. Additionally, the relevant lawyer failed to perform adequate client due diligence, source of funds checks, ongoing risk assessment checks, and maintain proper documentation on four separate client files.
Furthermore, the relevant lawyer, who is a Registered Foreign Lawyer (RFL), conducted reserved legal activities without proper supervision. Between December 2020 and January 2022, it was also noted that the relevant lawyer did not ensure the firm had a compliant AML firm-wide risk assessment, policies, controls, and procedures, or a nominated money laundering reporting officer as required by the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017.
Due to the severity of the conduct, which exhibited a repeated pattern of misconduct and failure to comply with anti-money laundering legislation, the SRA decided to impose a financial penalty of £18,750 on the relevant lawyer. The lawyer was also ordered to pay costs of £1,350. The decision took into account the need to protect public interest and maintain public confidence in the legal profession.
Mitigating factors were considered, such as the relevant lawyer admitting the misconduct in response to the SRA's notice and cooperating with the SRA. Additionally, the firm has since implemented a compliant AML firm-wide risk assessment and policies, controls, and procedures. An MLRO has been appointed and a supervisor for conveyancing work is now in place.