Reading-based law firm Harrison Thames Valley Solicitors LLP has been fined £25,000 by the Solicitors Regulation Authority (SRA) following ‘serious breaches’ of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017).
The fine came following an SRA investigation which found the firm did not appropriate measures to assess and mitigate risks related to money laundering and terrorist financing over a 6 year period from 2017 to 2023.
Between 26th June 2017 and 2nd November 2023 the SRA’s Anti Money Laundering (AML) team found:
- The firm did not have an adequate firm-wide risk assessment (FWRA) to identify and assess money laundering risks in compliance with Regulation 18 of the MLRs 2017.
- It lacked fully compliant Policies, Controls, and Procedures (PCPs) to manage those risks, contravening Regulation 19(1)(a) and 19(1)(b) of the MLRs 2017.
breaching the SRA’s Principles and Code of Conduct. The firm’s investigation was deemed serious under the SRA’s Enforcement Strategy due to its potential to harm public trust and confidence in the legal profession. However, the penalty was mitigated because:
- The firm cooperated fully with the investigation.
- It promptly addressed the breaches and implemented compliant AML documentation by 2 November 2023.
- No actual harm to clients or third parties was identified.
The £25,000 fine was calculated as 1.6% of the firm’s annual domestic turnover, placing the conduct in the lower range of Band C penalties. The firm was also ordered to pay £1,350 in costs. The SRA have said Harrison Thames Valley Solicitors LLP has since demonstrated full compliance with the MLRs 2017 and affirmed its commitment to maintaining effective risk management systems.
This is the latest firm to be fined for AML failings following a Birmingham ABS being fined £27,000 for similar breaches over a seven year period.
