Dentons UK and Middle East LLP

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

The SRA alleged that Dentons UK and Middle East LLP, while acting for Client A (a PEP from a high-risk jurisdiction, later convicted of fraud/embezzlement), failed to take adequate measures to establish his source of wealth and funds, breaching Regulation 14 MLRs 2007, Principles 6/7/8 and Outcome 7.5. The Tribunal found as a fact that the Firm breached Regulation 14 (relying on relationship partner Mr Chateau, who never asked Client A about his salary or shareholding), but held the breach was inadvertent, not systemic, and fell within the small category of wrongdoing not amounting to professional misconduct. Allegations 1.2 and 1.3 were dismissed; as Regulation 14 alone gave the Tribunal no sanctioning jurisdiction, the case was dismissed with no order as to costs. No dishonesty was alleged or found. The decision was later quashed and remitted on appeal.

Duties found breached:

• Report serious misconduct of others

Mitigating factors:

• Breach was entirely inadvertent
• Breach was not systemic
• Firm relied in good faith on the knowledge of relationship partner Mr Chateau, believing Regulation 14 had been satisfied
• Firm's AML systems and controls had been commended by the SRA as 'gold standard'
• Matter concerned only a single client and associated entities
• No allegation of actual money laundering, suspicion of money laundering, or failure to report
• No finding of intentional, reckless or systemic breach