Skip to main content
discipline 30 September 2026

The duty in context

No improper use of client money money

The lawyer must withdraw client money only for its proper purpose, must not overdraw a client's funds, and must not use the client account as a banking facility.

1,489 cases 67% strike-off avg suspension 21.4 mo avg fine 50,037 794 with dishonesty finding

How the codes express this duty

E&W Solicitors SRA Principles & Code SAR Rule 5.1; SAR Rule 3.3; SAR Rule 5.3 strong 1,008 cases
5.1 You only withdraw client money from a client account: (a) for the purpose for which it is being held; ... 3.3 You must not use a client account to provide banking facilities to clients or third parties. ... 5.3 You only withdraw client money from a client account if sufficient funds are held on behalf of that specific client or third party to make the payment.
E&W Barristers BSB Handbook no clear equivalent
Cayman Islands Legal Services Code 2026 P.7; R.9.2 partial
Attorneys-at-law shall protect client money and assets... An attorney-at-law and a recognised law entity shall safeguard money and assets entrusted to them by clients and others.
AU Solicitors Solicitors' Conduct Rules no clear equivalent
AU Barristers Uniform Barristers Rules no clear equivalent
IE Solicitors Law Society Guide Ch9 — Accounts regulations: General strong 90 cases
To use each client's money for that client's matter only, To use trust money only for the purpose of that trust... To establish and maintain proper accounting systems and proper internal control systems to ensure compliance with the regulations.
IE Barristers Bar Code of Conduct no clear equivalent
JM Attorneys Canons of Professional Ethics Canon VII(a) partial 118 cases
An Attorney shall comply with rules as may from time to time be prescribed by the General Legal Council relating to the keeping in separate accounts- (i) the funds of himself or any firm with which he is associated; and (ii) those of his clients.
JE Lawyers Law Society of Jersey Code P.7; R.7.4 a),c) partial
Members must protect client money and assets... Members must: a) identify, monitor and manage risks to money and assets entrusted to them by clients and others... c) ensure compliance with the Accounts Rules.
ON Lawyers LSO Rules of Prof. Conduct r 3.6-10; r 3.2-7.3 strong
3.6-10 A lawyer shall not appropriate any funds of the client held in trust or otherwise under the lawyer's control for or on account of fees except as permitted by the by-laws under the Law Society Act. [3.2-7.3 A lawyer shall not use their trust account for purposes not related to the provision of legal services.]
BC Lawyers BC Code r 3.6-10 strong 71 cases
A lawyer must not appropriate any client funds held in trust or otherwise under the lawyer's control for or on account of fees, except as permitted by the governing legislation.
NZ Lawyers Conduct & Client Care Rules r 10.5.2 / r 9.3 partial
A lawyer who receives funds on terms requiring the lawyer to hold the funds in a trust account as a stakeholder must adhere strictly to those terms and disburse the funds only in accordance with them. ... A lawyer who wishes to debit fees held in trust or to receive funds to cover fees in advance must comply with the requirements of regulations 9 and 10 of the Lawyers and Conveyancers Act (Trust Account) Regulations 2008.
SCO Solicitors LSS Standards of Conduct no clear equivalent
SG Lawyers Professional Conduct Rules 2015 r 16 (Client money) partial 19 cases
16 Client money
HK Solicitors Solicitors' Guide Principle 13.02 / Principle 4.02 Commentary 4 partial
A client account cheque must never be dishonoured. A solicitor must take care to ensure that any cheque for use in connection with his practice will be honoured upon presentation. ... Dishonour of a client account cheque will other than in exceptional circumstances indicate a breach of the Solicitors' Accounts Rules (Cap. 159 sub. leg. F). ... Under rule 9(2) of the Solicitors' Accounts Rules (Cap. 159 sub. leg. F), money received for or on account of an agreed fee which is paid by a client to his solicitor must be paid into an office account.
HK Barristers Bar Code of Conduct no clear equivalent

Cases dealing with this duty

Clear

1,489 decisions · link basis: found breached = a tribunal finding; rule cited = the mapped provision is cited in the decision; text match = high-precision text pattern

  • Sean Garvin Moses Osbourne
    GLC attorney 105 of 2022 2023-11-03 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered November 03, 2023. | Struck off, Restitution ordered | Disciplinary Committee decision delivered January 26, 2024. | Formal Order View PDF AM…

    Guilty of Professional Misconduct 1 PDF View decision
  • Gregory M.D. Lopez
    GLC attorney 148 of 2015 2023-10-27 found breached

    Struck off again | Disciplinary Committee decision delivered October 27, 2023. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered March 07, 2020. View PDF DECISION ON SANCTION OF THE DISCIP…

    Struck off again 1 PDF View decision
  • Andrew James Cutland
    SDT solicitor 12467/2023 2023-10-27 found breached

    Breaches, Client Money, Code of Conduct 2011, Dishonesty, Lack of Integrity, Solicitors' Accounts Rules, SRA Principles 2011

    Strike off 1 PDF View decision
  • Samantha Anne Lee
    SDT solicitor 12500/2023 2023-10-18 text match

    Lack of Integrity, Misappropriation of Client Account, Recklessness, Solicitors Accounts Rules 2011, SRA Authorisation Rules, SRA Principles 2011, SRA Principles 2019

    Strike off 1 PDF View decision
  • Henry Charles Adrian Syms
    SDT solicitor 12500/2023 2023-10-18 text match

    Lack of Integrity, Misappropriation of Client Account, Recklessness, Solicitors Accounts Rules 2011, SRA Authorisation Rules, SRA Principles 2011, SRA Principles 2019

    Strike off 1 PDF View decision
  • Sean Garvin Moses Osbourne
    GLC attorney 97 of 2021 2023-10-09 found breached

    Reprimanded, Restitution ordered, Fined | Disciplinary Committee decision delivered October 09, 2023 || Guilty of Professional Misconduct | Disciplinary Committee decision delivered September 25, 2023 View PDF FORMAL OR…

    Reprimanded, Restitution ordered, Fined 1 PDF View decision
  • Sean Garvin Moses Osbourne
    GLC attorney 97 of 2021 2023-10-09 found breached

    Reprimanded, Restitution ordered, Fined | Disciplinary Committee decision delivered October 09, 2023 || Guilty of Professional Misconduct | Disciplinary Committee decision delivered September 25, 2023 || Formal Order Vi…

    Reprimanded, Restitution ordered, Fined 1 PDF View decision
  • David Michael Simon
    LSBC lawyer 2023-10-05 found breached

    Rule 4-29 Admission of Misconduct and Undertaking to the Discipline Committee

    Rule 4-29 Admission of Misconduct and Undertaking to the Discipline Committee 1 PDF View decision
  • William Lorne Macdonald
    LSBC lawyer 2023-10-05 found breached

    Rule 4-29 Admission of Misconduct and Undertaking to the Discipline Committee

    Rule 4-29 Admission of Misconduct and Undertaking to the Discipline Committee 1 PDF View decision
  • Respondent AD
    SDT solicitor 12459/2023 2023-09-25 found breached rule cited

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Sean Garvin Moses Osbourne
    GLC attorney 97 of 2021 2023-09-25 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered September 25, 2023 || Reprimanded, Restitution ordered, Fined | Disciplinary Committee decision delivered October 09, 2023 || Formal Order Vi…

    Guilty of Professional Misconduct 2 PDFs View decision
  • Susan Lebreton-Towell
    SDT solicitor 12462/2023 2023-09-22 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Suspend - Fixed Period 1 PDF View decision
  • Prince Fomba Goba & Waqas Hassan & Syed Rafaqat Hussain & Bright Arrey Arrey-Mbi
    SDT solicitor 12435/2023 2023-08-24 found breached rule cited

    Breaches, Failures

    Allegations not substantiated, Strike off 1 PDF View decision
  • Mohammed Saleem
    SDT solicitor 12390/2022 2023-08-17 found breached

    Breaches, Failures

    Fine 1 PDF View decision
  • Kirsten Von Wedel
    SDT solicitor 12313/2022 2023-08-09 found breached rule cited

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Christopher Michael Haddock
    SDT solicitor 12401/2022 2023-08-01 found breached text match

    Breaches, Client Money, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Rosemary Ann Joyce
    SDT solicitor 12440/2023 2023-07-13 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Suspend - Fixed Period 1 PDF View decision
  • Glenn Charles Hurstfield
    SDT solicitor 12452/2023 2023-07-05 text match

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Rody Kelly-Corrigan
    LSI solicitor Rody Kelly-Corrigan Solicitors, The Glass House, 11 Coke Street, Smithfield, Dublin 7 2023-07-05 found breached

    In the matter of Rody Kelly Corrigan, a solicitor previously practising as Rody Kelly Corrigan, Solicitors, The Glass House, 11 Coke Street, Smithfield, Dublin 7, and in the matter of the Solicitors Acts 1954-2015 [2021…

    strike_off View decision
  • Christopher James Fry
    SDT solicitor 12379/2022 2023-06-28 found breached

    Breaches, Failures

    Fine 1 PDF View decision
  • Lyon Thomas Finkelstein
    LSBC lawyer 2023-06-28 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Stephen Harper
    SSDT solicitor Stephen Andrew Harper, c/o 37 Seaforth Avenue, Wick, Caithness 2023-06-22 found breached
    conditions No Appeal 2 PDFs View decision
  • Andrew Stevenson & Janet Stevenson
    SDT solicitor 12431/2023 2023-06-21 found breached

    Breaches, Solicitors' Accounts Rules

    Suspend - Fixed Period 1 PDF View decision
  • (unnamed)
    SDT solicitor 12430/2023 2023-06-14 text match
    S.44E/ S.46/Paragraph 14C Appeals 1 PDF View decision
  • Gregory Scott Yanke
    LSBC lawyer 2023-06-09 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision

Duty classification does not yet cover every jurisdiction (Ontario, New Zealand and Singapore decisions are indexed but not yet duty-classified), so counts here understate those corpora.