WGS Solicitors

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

WGS Solicitors admitted allegations that between 2018-2020 it allowed its client account to be used as a banking facility to facilitate high-value art purchases for a client (Person A1), and that from 2017-2021 it failed to comply with anti-money laundering obligations (CDD, EDD, ongoing monitoring and risk assessments) in matters relating to Person A1 and Person B1. The Tribunal approved an Agreed Outcome, finding no dishonesty, and imposed a fine of £25,258 (Indicative Fine Band Level 4, reflecting the Firm's turnover) plus costs of £18,000. There was no evidence of actual money laundering or financial loss; the case concerned failures of policies, controls and procedures.

Duties found breached:

• Uphold public trust in the profession
• No conflict between current clients
• No improper use of client money
• Firm governance, systems and compliance
• Not misrepresent regulated status

Aggravating factors:

• Misconduct continued over a lengthy period of time and was repeated, involving senior staff across management and fee-earning
• The Firm knew or ought reasonably to have known the conduct was in material breach of obligations to protect the public and the profession's reputation
• Firm had direct control over circumstances giving rise to misconduct
• Long-standing firm that should have been aware of statutory requirements and had proper procedures in place
• Allowed client account to be used as a banking facility

Mitigating factors:

• Voluntarily self-reported to the SRA and fully co-operated with the investigation
• Demonstrated insight and made full and frank admissions
• No allegation or evidence of actual money laundering or financial loss to any party
• Firm invested heavily (approx £292,504) in remediation and external advice
• Subsequent SRA AML Audit in April 2022 found no current or further historical problems
• No financial gain to the Firm (invoices credited/negated)