Cockshott Peck Lewis

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

Cockshott Peck Lewis, a recognised body, admitted three allegations of failing to comply with the Money Laundering Regulations 2017: no compliant firm-wide risk assessment for almost six years, failure to conduct client and matter risk assessments on four files, and failure to provide AML training to staff between 2015 and 2021. The Tribunal approved an agreed outcome, fining the firm £24,892.82 and ordering costs of £5,107.18. No dishonesty was alleged or found; the misconduct arose from an incorrect understanding of requirements rather than intentional non-compliance.

Duties found breached:

• No conflict between current clients
• Firm governance, systems and compliance
• AML and crime-prevention compliance

Aggravating factors:

• Total absence of a FWRA for almost 6 years
• Failure to conduct CMRAs over almost 5 years across multiple files
• Prolonged period (2015-2021) without AML training
• Inherent harm to reputation of the profession from breach of anti-money laundering rules

Mitigating factors:

• Breaches readily admitted
• Breaches unlikely to have created real risk given small firm of experienced solicitors
• CQS accreditation meant solicitors had compulsory training including on risks
• Misconduct resulted from incorrect understanding rather than intentional non-compliance
• No actual money laundering occurred