Huggins Lewis Foskett

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

Huggins Lewis Foskett, a recognised body, admitted four allegations relating to failures to comply with the Money Laundering Regulations 2017 over a period of over six years, including lacking an adequate firm wide risk assessment, inadequate policies/controls/procedures, failure to conduct documented client and matter risk assessments, and failure to establish an independent audit function. The Tribunal, dealing with the matter on the papers by agreed outcome, found the conduct very serious (Level 4) and imposed a fine of £58,000 plus costs of £20,000. No dishonesty was alleged or found.

Duties found breached:

• No conflict between current clients
• Report serious misconduct of others
• Not misrepresent regulated status

Aggravating factors:

• Misconduct continued over a lengthy period (over 6 years)
• Multiple repeated failures to comply with fundamental statutory requirements involving management and staff
• Firm knew or ought to have known conduct breached obligations
• No action taken after being made aware of SRA concerns in December 2022 until contacted again in January 2024
• High culpability - well-established firm doing significant higher-risk conveyancing work (over 64%)
• Guidance and warnings had been issued to the profession

Mitigating factors:

• Early full admissions avoiding a substantive hearing
• Breaches not intentional
• Cooperated with SRA and corrected policies and procedures, now regarded as compliant
• No evidence of actual money laundering or loss/damage
• Firm apologised and expressed regret
• Some insight demonstrated