Skip to main content
discipline 4 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

  • Richard Mallett & Sharon Mallett
    SDT solicitor 12102/2020 2020-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Nicholas Peter Whiffen
    SDT solicitor 12116/2020 2020-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Rebecca Jane Elliott
    SDT solicitor 12117/2020 2020-01-01 found breached text match

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Ebru Atas
    SDT solicitor 12136/2020 2020-01-01 found breached

    Breaches

    Strike off 1 PDF View decision
  • Matthew Edward Flynn
    SDT solicitor 12062/2020 2020-01-01 found breached

    Breaches, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Raymond Lawrence Toms
    SDT solicitor 12082/2020 2020-01-01 found breached

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Edward Anthony Bromet
    SDT solicitor 12048/2020 2020-01-01 found breached

    Breaches

    Strike off 1 PDF View decision
  • Petros Petrou & Stylianos Petrou
    SDT solicitor 12099/2020 2020-01-01 found breached text match

    Breaches, Failures, Solicitors' Accounts Rules

    Strike off, Suspend - Fixed Period 1 PDF View decision
  • Charles James Ete & Henry Onotere Mume
    SDT solicitor 12034/2020 2020-01-01 found breached

    Breaches, Client Money, Failures, Solicitors' Accounts Rules

    Reprimand, Strike off 1 PDF View decision
  • Karamjeet Kaur
    SDT solicitor 12053/2020 2020-01-01 found breached

    Breaches, Client Money, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Kirna Devi Madhas
    SDT solicitor 12058/2020 2020-01-01 found breached

    Breaches

    Strike off 1 PDF View decision
  • Munpreet Singh Virdee
    SDT solicitor 12052/2020 2020-01-01 found breached text match

    Breaches, Client Money, Solicitors' Accounts Rules

    Strike off 1 PDF View decision
  • Arlean D. Moreta Beckford
    GLC attorney 77 of 2013 2019-11-27 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered November 27, 2019. || Struck off | Disciplinary Committee decision delivered February 15, 2020. View PDF DECISION OF THE DISCIPLINARY COMMITT…

    Guilty of Professional Misconduct 1 PDF View decision
  • Howard A. Lettman
    GLC attorney 57 of 2008 2019-11-23 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered November 23, 2019. || Struck off, Restitution ordered | Disciplinary Committee decision delivered January 25, 2020 View PDF DECISION OF THE D…

    Guilty of Professional Misconduct 1 PDF View decision
  • Howard A. Lettman
    GLC attorney 215 of 2017 2019-11-13 found breached

    Struck off, Restitution Ordered | Disciplinary Committee decision delivered November 13, 2019. || Guilty of Professional Misconduct | Disciplinary Committee decision delivered July 20, 2019. View PDF View Formal Order D…

    Struck off, Restitution Ordered 2 PDFs View decision
  • Mark Lorrell
    BTAS barrister Lincoln's Inn 2019-11-13 found breached
    suspension Final 2 PDFs View decision
  • Homayoun Sebastian Nejat
    LSBC lawyer 2019-10-24 found breached

    Rule 4-29 Admission of Misconduct and Undertaking | Summary

    Rule 4-29 Admission of Misconduct and Undertaking | Summary 1 PDF View decision
  • Debayo Adedipe
    GLC attorney 26 of 2018 2019-10-23 found breached

    Struck off, Restitution Ordered | Disciplinary Committee decision delivered October 23, 2019. || Appeal dismissed | Court of Appeal decision delivered April 08, 2022. View PDF DECISION OF THE DISCIPLINARY COMMITTEE OF T…

    Struck off, Restitution Ordered 2 PDFs View decision
  • David Doyle
    LSI solicitor Doyle Associates, 56 Main Street, Rathfarnham, Dublin 14 2019-10-21 found breached

    In the matter of David Doyle, a solicitor previously practising as a partner in Doyle Associates, 56 Main Street, Rathfarnham, Dublin 14, and in the matter of the Solicitors Acts 1954-2015 [2019/DT09 and High Court refe…

    strike_off View decision
  • W. Anthony Pearson
    GLC attorney 10 of 2016 2019-10-12 found breached

    Guilty of Professional Misconduct | Disciplinary Committee decision delivered October 12, 2019. || Struck off | Disciplinary Committee decision delivered June 18, 2020. || Application for Suspension of Order Refused | D…

    Guilty of Professional Misconduct 1 PDF View decision
  • HELEN MARIE TOLSON
    LPBWA lawyer PO Box 3050 EAST PERTH WA 6892 VR 85 of 2019 2019-10-09 found breached

    Referral to Supreme Court (full bench) recommending name be removed from the roll of practitioners

    Referral to Supreme Court (full bench) recommending name be removed from the roll of practitioners 1 PDF View decision
  • RONALD WILLIAM BOWER
    LPBWA lawyer Level 4, Irwin Chambers 16 Irwin Street PERTH WA 6000 Legal Profession Complaints Committee v Bower [2019] WASC 2019-07-31 found breached

    Struck Off the Roll of Practitioners

    Struck Off the Roll of Practitioners 1 PDF View decision
  • NICHOLAS NEIL PETER OUD
    LPBWA lawyer PO Box 326 BURSWOOD WA 6100 Legal Profession Complaints Committee v Oud [2019] WASC 2019-07-31 found breached

    Struck Off the Roll of Practitioners

    Struck Off the Roll of Practitioners 1 PDF View decision
  • Stuart, Andrew Graham
    OLSC solicitor Stuart & Mills [2019] NSWCATOD 108 2019-07-05 found breached

    1. Misappropriated trust funds 2. Breached section 255 LPA 2004 - Holding, disbursing and accounting for trust money 3. Breached section 263 LPA 2004 - Reporting certain irregularities and suspected irregularities 4. Br…

    Costs Removal of lawyer's name from the Roll of Local Lawyers $0.00 1 PDF View decision
  • Davidson, Chona Encarnacion Castillo
    OLSC solicitor Castillo Davidson & Associates [2019] NSWCATOD 105 2019-07-03 found breached

    Professional Misconduct 1. Misappropriation of trust funds 2. Breach of section 146 LPUL - Intermixing trust money 3. Breach section 138 LPUL - Holding trust money 4. Breach of section 148 LPUL - Deficiency in trust acc…

    Costs Issued with a restricted practising certificate (Disciplinary Action 30/06/2020) $0.00 2 PDFs 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.