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What I find particular disturbing about the decision of the SRA is that the money-laundering directives only came in approximately in 2003 and therefore the solicitors are being punished for something done as far back as 1999 and a rule which was only emphasised after 2011 and which did not appear in the Solicitors Accounts Rules 1998 - extract from SRA Warning Notice December 2014:
"Since 1998, guidance note (ix) to Rule 15 of the Solicitors Accounts Rules 1998 has warned solicitors of the need to exercise caution if asked to provide banking facilities through a client account and in 2004 the note was amended to state expressly that solicitors "should not provide banking facilities through a client account". In 2011, the guidance note was elevated to an Accounts Rule (Rule 14.5 of the SRA Accounts Rules 2011)."

Looks to me like retrospective disciplinary action.

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