Tolhurst Fisher LLP

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

Tolhurst Fisher LLP, a long-established firm doing significant conveyancing work, admitted six allegations of failing to comply with anti-money laundering requirements (MLRs 2007 and 2017) over a period exceeding 15 years, including failures to have a firm wide risk assessment, adequate policies/controls/procedures, client and matter risk assessments, and source of funds inquiries on two specific files. The matter was resolved on the papers via an agreed outcome. No dishonesty was alleged or found. The Tribunal categorised the misconduct as very serious (Level 4), noting no evidence of actual harm but significant risk to the reputation of the profession, and imposed a fine of £120,000 plus costs of £25,290.

Duties found breached:

• Proper basis for allegations
• Maintain competence and CPD
• Firm governance, systems and compliance
• Not misrepresent regulated status

Aggravating factors:

• Misconduct continued over a lengthy period (over 15 years) involving repeated failures across management and staff
• Firm knew or ought reasonably to have known its conduct was in material breach of obligations
• Well-established firm of size and resources undertaking significant conveyancing (higher risk sector)
• High level of culpability with direct control over relevant matters
• Periods where firm had no safeguards at all

Mitigating factors:

• Full cooperation with the SRA investigation
• Full and frank admissions at an early stage, avoiding a contested hearing
• Active steps taken to remedy the breaches
• Previously unblemished regulatory record
• No evidence of actual harm caused