Simpson Thacher & Bartlett LLP

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

Simpson Thacher & Bartlett LLP, the relevant person with responsibility for AML compliance, admitted three allegations arising from an SRA AML supervision review: failing to have a firm-wide risk assessment (Reg 18), failing to have fully compliant policies/controls/procedures (Reg 19), and failing to have compliant client/matter risk assessments on four files (Reg 28). No actual harm and low risk of money laundering were found, but prolonged non-compliance risked harm to the profession's reputation. No dishonesty alleged or found. By Agreed Outcome the Tribunal imposed a £300,000 fine and £62,000 costs.

Duties found breached:

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

Aggravating factors:

• Length of time for which the breaches continued
• A firm of its size and resources ought reasonably to have known the misconduct was a material breach of its obligations

Mitigating factors:

• Full cooperation with the investigation
• Early admission of misconduct, avoiding a contested hearing
• Actively took steps to remedy the breaches
• Unblemished regulatory record