(unnamed respondent)
Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision
Scott-Moncrieff and Associates Limited, a licensed body (ABS), was found by an SRA Adjudicator to have committed Allegations 1 and 2: failing over several years to have a compliant firm-wide AML risk assessment and policies/controls/procedures under the MLRs 2017, and allowing some $23m to pass into and out of its client account in the Kamaz matter other than in respect of regulated services, thereby providing banking facilities contrary to Rule 3.3 of the SRA Accounts Rules 2019. Allegation 3 (CDD failings) was not proven. The Adjudicator imposed a financial penalty of £68,000 (to be published) plus £1,350 investigation costs, upheld on internal review. The Firm appealed to the SDT challenging the Rule 3.3 finding and the level/proportionality of the penalty, arguing exceptional circumstances given its atypical ABS structure (70% profit to consultants), low proportion of in-scope work, absence of actual harm, remedial steps taken, and that the same penalty was retained despite Allegation 3 not being proven. The decision text excerpt does not record the Tribunal's final determination on the appeal. No express finding of dishonesty was made.
Duties found breached: