Decision record
Teacher Stern LLP; Claire Rollo; Sacha Rifkin
Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision
The SRA alleged that the Firm and two solicitors caused or allowed payments from the client account otherwise than in respect of an underlying transaction or normal regulated activity, breaching Rule 14.5 SAR 2011 and various Principles (with recklessness alleged as an aggravating feature against the Second Respondent). The matter arose from a 2020 self-report concerning payments made 2014-2016 for Clients A (£591,507.28) and B (€23,563,782.53). The SRA amended its case on the first day, reducing questionable transactions from 23 to 4. The Tribunal found the SRA's investigation was inadequate ('accusation without evidence'), effectively reversing the burden of proof, and that the scope of Rule 14.5 was unclear at the relevant time. The payments were connected to underlying legal transactions. All allegations were dismissed. The Tribunal found no probative value in an email describing being 'like being a bank for all our clients'. On costs, the Tribunal found good reason to depart from the usual position that no costs are ordered against a regulator, criticising the SRA's conduct at the substantive hearing (multiple confusing versions of the Rule 12 statement, persistence despite obvious weaknesses, unclear whether allegations were still pursued) as a 'shambles', but limited the costs award to the period 20-22 November 2024, subject to detailed assessment.