William Joseph Harris

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

William Joseph Harris, a sole practitioner and his firm's COLP, COFA, MLRO and MLCO, admitted six allegations arising from widespread and fundamental failures over a six-year period to comply with the MLRs 2017 and SRA Accounts Rules. He dishonestly and inaccurately confirmed to the SRA in December 2019 that his firm had a Firm Wide Risk Assessment when it did not, failed to maintain compliant AML risk assessments and policies, failed to scrutinise source of funds for 63 conveyancing clients, lacked an adequate CDD system, failed to return over £100,000 in 54 residual client balances, and failed to obtain Accountant's Reports for three accounting periods. The firm was exposed to £8.8 million in unverified funds. The matter was dealt with on the papers by way of an Agreed Outcome; the alternative recklessness allegation (1.2) was withdrawn since dishonesty was admitted. The Tribunal struck the Respondent off the Roll and ordered costs of £29,775.84.

Duties found breached:

• No conflict between current clients
• No improper use of client money
• Accounting records, reconciliation and reports
• Firm governance, systems and compliance
• Good faith and courtesy to colleagues