Simpson Thacher & Bartlett LLP

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

Simpson Thacher & Bartlett LLP admitted three allegations of breaching the Money Laundering Regulations 2017 by failing to have a firm-wide risk assessment, fully compliant policies/controls/procedures, and compliant client/matter risk assessments over lengthy periods. The Tribunal, dealing with the matter by agreed outcome, found low risk of harm and no actual harm but that the breaches risked harm to the profession's reputation. No dishonesty was found. A fine of £300,000 was imposed plus £62,000 costs.

Duties found breached:

• No conflict between current clients
• No baseless or threatened misconduct report
• Not misrepresent regulated status

Aggravating factors:

• Breaches continued over a lengthy period of time
• A firm of its size and resources ought reasonably to have known the misconduct was a material breach of its obligations

Mitigating factors:

• Full cooperation with the investigation
• Early admission of misconduct, avoiding a contested hearing
• Active steps taken to remedy the breaches
• Unblemished regulatory record