Carter Devile

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

The Solicitors Disciplinary Tribunal dealt on the papers with an agreed outcome concerning Carter Devile, a former recognised body. The firm admitted five breaches of the Money Laundering Regulations (2007 and 2017 MLRs), including failing to have a firm-wide risk assessment, failing to establish AML policies, controls and procedures, and failing to provide adequate staff AML training over several years. The firm was managed by Mr Devile (MLRO) and Ms Mead (COLP/COFA/MLCO); Ms Mead, who held compliance responsibilities, passed away in 2023 and the partnership ceased to be a recognised body. Given the surviving partner's limited personal culpability, lack of direct involvement, and genuine belief the firm was compliant, the Tribunal found low seriousness and culpability and made No Order, but ordered the Respondent to pay £5,000 in costs. No dishonesty was found or alleged.

Duties found breached:

• AML and crime-prevention compliance
• Not misrepresent regulated status

Aggravating factors:

• Sustained and persistent failure spanning several years
• Absence of a firm-wide risk assessment impacted ability to put in place appropriate policies, controls and procedures
• Firm undertook substantial conveyancing work within scope of the MLRs

Mitigating factors:

• Mr Devile had limited personal culpability and no detailed knowledge of the subject matter files
• Mr Devile did not have day-to-day conduct of the files and was not based at the relevant office
• Compliance responsibilities (COLP/COFA/MLCO) rested with Ms Mead, who has since passed away
• Mr Devile genuinely believed the firm was compliant at the material time
• The former partnership is now dissolved and the successor practice operates with a different governance structure
• Matter resolved by agreed outcome