Decision record
WGS Solicitors
Allegation / charges
Breaches, Code of Conduct for Firms 2019, Code of Conduct for Solicitors, REL's & RFL's 2019, SRA Principles 2011, SRA Principles 2019
Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision
WGS Solicitors admitted allegations that between 2018-2020 it allowed its client account to be used as a banking facility to facilitate high-value art purchases for a client (Person A1), and that from 2017-2021 it failed to comply with anti-money laundering obligations (CDD, EDD, ongoing monitoring and risk assessments) in matters relating to Person A1 and Person B1. The Tribunal approved an Agreed Outcome, finding no dishonesty, and imposed a fine of £25,258 (Indicative Fine Band Level 4, reflecting the Firm's turnover) plus costs of £18,000. There was no evidence of actual money laundering or financial loss; the case concerned failures of policies, controls and procedures.
Duties found breached:
- Uphold public trust in the profession
- No conflict between current clients
- No improper use of client money
- Firm governance, systems and compliance
- Not misrepresent regulated status
Aggravating factors:
- Misconduct continued over a lengthy period of time and was repeated, involving senior staff across management and fee-earning
- The Firm knew or ought reasonably to have known the conduct was in material breach of obligations to protect the public and the profession's reputation
- Firm had direct control over circumstances giving rise to misconduct
- Long-standing firm that should have been aware of statutory requirements and had proper procedures in place
- Allowed client account to be used as a banking facility
Mitigating factors:
- Voluntarily self-reported to the SRA and fully co-operated with the investigation
- Demonstrated insight and made full and frank admissions
- No allegation or evidence of actual money laundering or financial loss to any party
- Firm invested heavily (approx £292,504) in remediation and external advice
- Subsequent SRA AML Audit in April 2022 found no current or further historical problems
- No financial gain to the Firm (invoices credited/negated)
Codes & rules applied
Duties engaged
- Integrity
- No bribery or improper gifts
- Personal probity and fitness to practise
- Uphold public trust in the profession
- No unlawful discrimination or harassment
- No conflict between current clients
- No improper use of client money
- Maintain competence and CPD
- Firm governance, systems and compliance
- AML and crime-prevention compliance
- Not misrepresent regulated status