Tolhurst Fisher LLP

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

Tolhurst Fisher LLP, a recognised body, admitted six allegations of failing to comply with anti-money laundering regulations over a period spanning more than 15 years, including failure to have a firm wide risk assessment, adequate policies/controls/procedures, client and matter risk assessments, and source of funds inquiries. The Tribunal, dealing with the matter on the papers by way of agreed outcome, found the admissions properly made. No dishonesty was alleged or found; culpability was high but no actual harm proven. The Tribunal imposed an agreed fine of £120,000 (very serious/Level 4) plus costs of £25,290.

Duties found breached:

• Firm governance, systems and compliance
• Handle inadvertently received material
• Proper basis for allegations

Aggravating factors:

• Misconduct continued over a lengthy period (over 15 years across two sets of regulations)
• Multiple failures to comply with fundamental statutory requirements involving management and staff across the firm
• Firm knew or ought reasonably to have known the misconduct was in material breach of its obligations
• Conveyancing is a higher risk sector for money laundering
• Well-established firm with significant resources

Mitigating factors:

• Full cooperation with the SRA investigation
• Full and frank admissions at an early stage, avoiding a contested hearing
• Active steps taken to remedy the admitted breaches
• Previously unblemished regulatory record
• No evidence of actual harm caused