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discipline 3 October 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.

1,577 cases 67% strike-off avg suspension 14.0 mo avg fine 62,331 864 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 1,062 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 137 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 66 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 23 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

1,577 decisions · link basis: found breached = a tribunal finding; rule cited = the mapped provision is cited in the decision; text match = high-precision text pattern

  • Eric Kawoya Kabuye
    SDT solicitor 12703/2024 2025-12-12 found breached rule cited

    Client Money, Code of Conduct for Firms 2019, Code of Conduct for Solicitors, REL's & RFL's 2019, Solicitors Accounts Rules 2019, SRA Principles 2019

    Suspended period of Suspension 1 PDF View decision
  • Siobhan Sullivan
    SSDT solicitor Siobhan Sullivan, c/o Bridge Legal Limited, Carlton Buildings, 63 Carlton Place, Glasgow 2025-12-04 found breached
    strike_off No Appeal 1 PDF View decision
  • Yeo Yao Hui, Charles (Yang Yaohui)
    SG-DT lawyer M/S L F Violet Netto; Whitefield Law Corporation; S K Kumar Law Practice LLP 2025-11-28 found breached
    Struck off the roll with immediate effect 1 PDF View decision
  • (unnamed)
    SDT solicitor 12787/2025 2025-11-18 found breached

    Client Money, Code of Conduct for Solicitors, REL's & RFL's 2019, Money Laundering Regulations, Solicitors' Accounts Rules

    Restoration to the Roll - Refused 1 PDF View decision
  • Zhou, Ren
    OLSC solicitor Ren Zhou Group Pty Ltd trading as Ren Zhou Lawyers 2025-11-06 found breached

    The solicitor, as principal of a law practice: Caused a deficiency in the trust account by withdrawing trust money for payment of legal costs without complying with legislative requirements Mixed trust money with other …

    Fine Reprimand Satisfactory completion of a Practice Management Course $2,000.00 About ​ About the OLSC The Commissioner History Mission statement Structure Contact ​ Contact the OLSC Give us your feedback: online surveys Access to information (GIPAA) Community information ​ Information for lawyers Fact sheets FAQs Other regulatory and complaint-handling organisations Contact LawAccess NSW for legal information " You and Your Lawyer", Hot ​​Topics 78 Legal Information Access Centre (LIAC), State Library of NSW​ , provides access to information about the law in NSW regarding your lawyer Privacy Copyright and Disclaimer Website accessibility View decision
  • Kin Ip Lo
    LSBC lawyer 2025-11-04 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Stefanie Anne O’Bryen
    SDT solicitor 12611/2024 2025-11-03 found breached rule cited

    Breaches, Code of Conduct for Firms 2019, Code of Conduct for Solicitors, REL's & RFL's 2019, Money Laundering Regulations, Solicitors Accounts Rules 2019

    Suspend - Fixed Period 1 PDF View decision
  • Gordon Wayne Ruley
    LSBC lawyer 2025-10-24 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Charles Ogbonna Azotam
    SDT solicitor 12777/2025 2025-10-24 found breached rule cited

    Client Money, Code of Conduct for Solicitors, REL's & RFL's 2019, Solicitors' Accounts Rules, SRA Principles 2019

    Strike off 1 PDF View decision
  • Gow, Samantha Catherine
    OLSC solicitor 1189 Properties Pty Ltd T/A Gow Group - Global Legal Services [2025] NSWCA 232 2025-10-23 found breached

    The Prothonotary relied on 27 particulars spanning the period 2014-2024. These included: 1. 2014 convictions in Queensland for breach of bail, being drunk in a public place, and committing public nuisance; 2. failure be…

    Costs Removal of lawyer’s name from the Roll of Australian lawyers $0.00 1 PDF View decision
  • David James Chalcraft
    SDT solicitor 12620/2024 2025-10-06 found breached

    Code of Conduct 2011, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Solicitors Accounts Rules 2011, Solicitors Accounts Rules 2019, SRA Principles 2011, SRA Principles 2019

    Strike off 1 PDF View decision
  • Anbananden Sooben
    SDT solicitor 12716/2024 2025-10-06 found breached

    Code of Conduct for Solicitors, REL's & RFL's 2019, Recklessness, Solicitors Accounts Rules 2019, SRA Principles 2019

    Suspend - Fixed Period 1 PDF View decision
  • Grubisa, Dominique
    OLSC solicitor DGI Lawyers Pty Ltd [2025] NSWCATOD 127 2025-10-01 found breached

    Proceedings no. 2022/00387737 (First Application) 1. Mrs Grubisa was the principal of a law practice which had lay associates who were disqualified persons under the Legal Profession Uniform Law (NSW) and who were not a…

    Costs Order recommending removal of lawyer's name from the Roll of Australian Lawyers $0.00 1 PDF View decision
  • Roderick Wayne Kirkham
    LSBC lawyer 2025-09-09 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Michael Andrew Christ
    LSBC lawyer 2025-08-26 found breached

    Rule 3-7.1 Consent Agreement

    Rule 3-7.1 Consent Agreement 1 PDF View decision
  • Matthew David McCormick
    LSC-QLD solicitor McCormick's Law 2025-08-26 found breached

    The Respondent’s conduct identified in Charges 2 and 6 in the discipline application is proved and is found to constitute professional misconduct.

    Struck off 2 PDFs View decision
  • Elizabeth Jane Radcliffe
    SDT solicitor 12700/2024 2025-08-22 found breached rule cited

    Breaches, Client Money, Code of Conduct for Solicitors, REL's & RFL's 2019, Solicitors Accounts Rules 2019, SRA Principles 2011, SRA Principles 2019

    Suspend - Fixed Period 1 PDF View decision
  • (unnamed)
    SDT solicitor 12740/2025 2025-08-22 rule cited
    Variation of Conditions on Practising Certificate 1 PDF View decision
  • Yusuf Jamal Siddiqui
    SDT solicitor 12637/2024 2025-08-22 found breached

    Breaches, Client Money, Code of Conduct for Solicitors, REL's & RFL's 2019, Solicitors Accounts Rules 2019, SRA Principles 2019

    Suspend - Fixed Period 1 PDF View decision
  • Harry Francis Cottam
    SDT solicitor 12336/2022 2025-07-31 found breached

    Dishonesty, Lack of Integrity, Solicitors Accounts Rules 2011, SRA Principles 2011

    Strike off 1 PDF View decision
  • Matthew Stephen Becker
    SDT solicitor 12692/2024 2025-07-25 found breached

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

    Strike off 1 PDF View decision
  • William Joseph Harris
    SDT solicitor 12738/2025 2025-07-25 found breached

    Breaches, Client Money, Code of Conduct for Solicitors, REL's & RFL's 2019, Dishonesty, Lack of Integrity, Money Laundering Regulations, Solicitors Accounts Rules 2019, SRA Principles 2011, SRA Principles 2019

    Strike off 1 PDF View decision
  • (unnamed)
    SDT solicitor 12723/2025 2025-07-25 found breached
    Restoration to the Roll - Refused 1 PDF View decision
  • Rory Peter Heddle Fordyce
    SDT solicitor 12560/2024 2025-07-25 found breached rule cited

    Breaches, Client Money, Code of Conduct 2011, Money Laundering Regulations, Solicitors Accounts Rules 2011, Solicitors Accounts Rules 2019, SRA Principles 2011, SRA Principles 2019

    Fine 1 PDF View decision
  • Mahony, John Francis Thomas
    OLSC solicitor Mahony Law 2025-07-24 found breached

    Allegation 1: The Respondent Solicitor did not properly account for monies received on trust on behalf of the Complainant Allegation 2: The Respondent Solicitor failed to provide a costs agreement and/or costs disclosur…

    Fine Lawyer to undertake and complete further ethics education Reprimand Within three (3) months from notification of the Committee’s determination, the Respondent Solicitor provide a written apology to the Complainant in a form approved by the Director, Legal Regulation (s299(1)(c) of the Legal Profession Uniform Law) $10,000.00 About ​ About the OLSC The Commissioner History Mission statement Structure Contact ​ Contact the OLSC Give us your feedback: online surveys Access to information (GIPAA) Community information ​ Information for lawyers Fact sheets FAQs Other regulatory and complaint-handling organisations Contact LawAccess NSW for legal information " You and Your Lawyer", Hot ​​Topics 78 Legal Information Access Centre (LIAC), State Library of NSW​ , provides access to information about the law in NSW regarding your lawyer Privacy Copyright and Disclaimer Website accessibility 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.