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 of breaching the Money Laundering Regulations 2017 between June 2017 and January 2024: failing to have a compliant firm wide risk assessment, failing to have/review/monitor policies controls and procedures, failing to conduct client and matter risk assessments, and failing to establish an independent audit. These also breached the SRA Principles and Codes of Conduct. The Tribunal found the conduct very serious but noted no dishonesty. It imposed a fine of £58,000 and costs of £20,000 via Agreed Outcome.

Duties found breached:

• Good faith and courtesy to colleagues
• Non-discriminatory acceptance and cab-rank
• Not misrepresent regulated status

Aggravating factors:

• Misconduct was very serious and persisted for a long time
• No apparent reason for non-compliance with the regulations
• It was a matter of luck the firm was not targeted by criminals exploiting the AML deficiencies

Mitigating factors:

• Full admissions at an early stage demonstrating some insight