Carter Devile
Allegation / charges
Breaches, Code of Conduct 2011, Code of Conduct for Firms 2019, Money Laundering Regulations, SRA Principles 2011
Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision
Carter Devile, a former recognised body, admitted multiple anti-money laundering compliance failures between 2015 and 2021, including failing to have a firm-wide risk assessment, failing to maintain appropriate AML policies and procedures, and failing to provide regular AML training to staff. The firm ceased operating as an authorised partnership in October 2023 following the death of the partner who held the COLP/COFA/MLCO roles, continuing as a sole practice. The matter was resolved by Agreed Outcome on the papers. Given the Respondent's limited personal culpability, lack of direct involvement, and genuine belief in compliance, the Tribunal found seriousness and culpability to be low and made No Order, but ordered costs of £5,000.
Duties found breached:
- AML and crime-prevention compliance
- Firm governance, systems and compliance
- No improper communication with the court
- Not misrepresent regulated status
Mitigating factors:
- Limited personal culpability
- Lack of direct involvement in the subject matter files
- Genuine belief that the Firm was compliant at the material time
- Admissions properly made / resolved by Agreed Outcome