Dentons UK and Middle East LLP

Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision

The SRA alleged that Dentons UK and Middle East LLP, while acting for Client A (a PEP and former Bank Chairman from a high-risk jurisdiction, later convicted of fraud/embezzlement abroad) between 1 May 2013 and 24 January 2017, failed to take adequate measures to establish his source of wealth/funds. The Tribunal found as a fact that the Firm had breached Regulation 14 of the MLRs 2007 (allegation 1.1), but found the breach did not amount to a breach of Principles 6, 7 or 8 or Outcome 7.5 of the Code (allegations 1.2 and 1.3). As the MLRs did not fall within the Principles, Code or professional rules, the Tribunal held it had no jurisdiction to impose a sanction absent a finding of professional misconduct, and accordingly dismissed the case. No express finding of dishonesty was made. (Note: subsequently appealed; quashing upheld by the Court of Appeal on a narrower basis and remitted to a freshly constituted Panel.)

Duties found breached:

• No improper use of client money