Law firm fined £120,000 and costs of £25,290 for AML failures

Tolhurst Fisher LLP was sanctioned following an agreed outcome between the firm and the Solicitors Regulation Authority.

• https://guidance.sra.org.uk/consumers/solicitor-check/463244/

A Solicitors Disciplinary Tribunal report, published on Friday, shows the firm failed to implement a firm-wide risk assessment between June 2017 and January 2024, in breach of money laundering regulations.

• https://solicitorstribunal.org.uk/wp-content/uploads/2025/03/12720-2025.Tolhurst-Fisher.pdf

While no evidence of money laundering or financial crime was identified, the tribunal noted that the breaches posed a risk to the public and confidence.

According to the document, the firm

• Failed to “conduct or have in place” a risk assessment and
• “Thereby failed to take appropriate steps to identify and assess the risks of money laundering and terrorist funding”.

The findings state:

• “Despite warnings, the misconduct complained of continued and included periods when the firm had no, as opposed to no adequate, appropriate safeguards in place as required by the regulations.”

Tolhurst Fisher

• Accepted the findings and cooperated with the Solicitors Regulation Authority throughout the investigation. The firm has also taken active steps to remedy the admitted breaches.
• Admitted all six allegations early and cooperated with the investigation.
• Was ordered to pay a fine of £120,000 and costs of £25,290.

Mark Francis, managing partner of Tolhurst Fisher:

• “We note the SDT’s Order, which followed an agreed outcome between this firm and the Solicitors Regulatory Authority.
• The anti-money laundering policy and procedure breaches on our part are wholly regrettable.
• We understand the importance of the principles behind the regulations and our part in ensuring that the legal profession's important role in preventing money laundering is upheld.
• “It is important to note that the SRA found no evidence of money laundering and our clients suffered no losses from these breaches.
• As soon as the SRA identified the technical breaches, we accepted responsibility and co-operated fully.
• We also undertook immediate remedial action, including appointing an external consultant, introducing new policies and procedures, a new management structure, regular firmwide training and a monitoring and review process.”
• "The SRA acknowledged our prompt response and confirmed, over a year ago, that our updated policies and procedures are compliant, a fact underlined in the independent report we commissioned at the beginning of this year.
• "AML compliance is a fundamental part of the operation of this firm, and we have learned a great deal since the initial SRA investigation. We would encourage other firms to do likewise.”

Source

https://www.echo-news.co.uk/news/25169587.southend-law-firm-fined-120-000-money-failures/

https://solicitorstribunal.org.uk/wp-content/uploads/2025/03/12720-2025.Tolhurst-Fisher.pdf