A solicitor has been fined just over £4,000 after he was found to have transferred around £9.1m without instruction and ‘caused and materially contributed’ to the firm’s money laundering regulation failures.
Jeremy Bennett, admitted in October 1989, was the former owner and solicitor of Sheffield-based firm 7 Legal and Finance Limited. He was sanctioned as part of an agreed decision with the Solicitors Regulation Authority. Bennett was fined £4,273, agreed to the publication of the agreement on the SRA website and must pay costs of the investigation of £600.
The regulator received a report from Pennine Law Limited, where Bennett was working as a consultant, in January 2024. An SRA investigation ‘identified areas of concern in relation to Mr Bennett’s compliance’ with money laundering regulations, SRA Accounts Rules, SRA Principles and the Code of Conduct.
Bennett was instructed by ‘Client A’ to assist in the creation of a trust structure. Between 28 November 2022 and 6 December 2022, the firm’s client account received three deposits from the beneficiaries of the trust, totalling £9,141,862.47. The SRA said Bennett ‘then allowed the funds to be dispersed from the firm’s client account to two third parties'. There was no correlating ledger on the file itemising the transactions, it said.
Read more
‘The receipt by solicitors of payments into their client account could provide legitimacy and a veneer of authenticity to the transactions and money movements, which is why it is not permitted for solicitors to provide banking facilities, and yet Mr Bennett permitted this resulting in the alleged misappropriation of £9.1m.’
There was no documented client and matter risk assessment on the file, the regulator said, noting that Bennett ‘confirmed he had kept a mental note of the risk assessment as he knew the client’.
‘Mr Bennett accepted that the matter was high risk for the firm, in comparison to the work it was normally conducting. As such, enhanced customer due diligence and ongoing monitoring was required, which can include source of funds and wealth checks. We agree that the matter was high risk and therefore required a higher level of scrutiny.’
Fining Bennett, the regulator acknowledged he had no regulatory history of concern, is no longer a practising solicitor, cooperated with the SRA’s investigation, and the incident was a ‘one-off…with no indication of a pattern of poor misconduct’. He made no financial gain or received any other benefit as a result of the conduct.
Bennett was fined £4,273, taking into consideration his gross annual income and his mitigation.
