Tolhurst Fisher LLP

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

Duties found breached:

• Firm governance, systems and compliance
• Good faith and courtesy to colleagues
• No conflict between current clients
• Non-discriminatory acceptance and cab-rank
• Not misrepresent regulated status

Aggravating factors:

• Misconduct continued over a lengthy period of over 15 years spanning two sets of Money Laundering Regulations
• Repeated multiple failures to comply with fundamental statutory requirements involving management and staff across the firm
• Periods where the firm had no safeguards at all in place, not merely inadequate ones
• A well-established firm of its size and resources ought reasonably to have known its conduct breached its obligations
• Work concentrated in conveyancing, a higher-risk sector for money laundering

Mitigating factors:

• Full cooperation with the SRA investigation
• Admission of misconduct, avoiding a contested hearing
• Active steps taken to remedy the admitted breaches
• Previously unblemished regulatory record
• No evidence of actual harm caused