Decision record
Simpson Thacher & Bartlett LLP
JurisdictionEngland & Wales
BodySolicitors Disciplinary Tribunal (SDT)
Professionsolicitor
Case number12639/2024
Date21/03/2025
OutcomeFine
Allegation / charges
Breaches, Code of Conduct 2011, Code of Conduct for Firms 2019, Money Laundering Regulations, SRA Principles 2011, SRA Principles 2019
Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision
SanctionFine
FineGBP 300,000
CostsGBP 62,000
Dishonesty foundNo
Simpson Thacher & Bartlett LLP admitted three allegations of breaching the Money Laundering Regulations 2017 by failing to have a firm-wide risk assessment, fully compliant policies/controls/procedures, and compliant client/matter risk assessments over lengthy periods. The Tribunal, dealing with the matter by agreed outcome, found low risk of harm and no actual harm but that the breaches risked harm to the profession's reputation. No dishonesty was found. A fine of £300,000 was imposed plus £62,000 costs.
Duties found breached:
- No conflict between current clients
- No baseless or threatened misconduct report
- Not misrepresent regulated status
Aggravating factors:
- Breaches continued over a lengthy period of time
- 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
- Active steps taken to remedy the breaches
- Unblemished regulatory record
Codes & rules applied
Duties engaged
- 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
- Firm governance, systems and compliance
- No baseless or threatened misconduct report
- AML and crime-prevention compliance
- Not misrepresent regulated status