Decisions and interventions

The SDT ordered that the respondent, a firm of solicitors, should pay a fine of £120,000.  

From 26 June 2017 to 25 November 2019, the respondent had failed to conduct or have in place a firm-wide risk assessment (FWRA), and had thereby failed to take appropriate steps to identify and assess the risks of money laundering and terrorist financing to which its business was subject, as required by regulation 18 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017 (MLRs). It thereby acted in breach of principles 6, 7 and 8 of the SRA Principles 2011, and had failed to achieve outcomes 7.2 and 7.5 of the SRA Code of Conduct 2011 (SCC 2011).

From 26 November 2019 to 23 January 2024, it had failed to conduct or have in place an appropriate FWRA, which complied with the requirements of regulation 18 of the MLRs, to take appropriate steps to identify and assess the risks of money laundering and terrorist financing to which its business was subject. It had thereby acted in breach of principle 2 of the SRA Principles and paragraphs 2.1(a) and 3.1 of the SRA Code of Conduct for Firms.

Between 15 December 2007 and December 2012, it had failed to establish appropriate and risk-sensitive policies and procedures relating to customer due diligence measures and ongoing monitoring, reporting, record-keeping, internal control, risk assessment and management; the monitoring and management of compliance with, and the internal communication of, such policies and procedures, in order to prevent activities related to money laundering and terrorist financing, pursuant to regulation 20(1) of the Money Laundering Regulations 2007. Accordingly, it had acted in breach of rules 1.06 and 5.01(b) of the Solicitors Code of Conduct 2007 and principles 6, 7 and 8 of the 2011 Principles, and had failed to achieve outcomes 7.2 and 7.5 of the SCC 2011.

The respondent had failed between December 2012 and 25 June 2017 to maintain appropriate and risk-sensitive policies and procedures relating to customer due diligence measures and ongoing monitoring, reporting, record-keeping, internal control, risk assessment and management; the monitoring and management of compliance with, and the internal communication of, such policies and procedures, in order to prevent activities related to money laundering and terrorist financing, pursuant to regulation 20(1) of the MLRs 2007. Between 26 June 2017 to 29 January 2024, the firm failed to (i) have policies, controls and procedures in place which complied with the requirements of regulation 19(1)(a) of the MLRs; (ii) regularly review and update its PCPs in compliance with regulation 19(1)(b) of the MLRs; and (iii) monitor and manage compliance with its PCPs in compliance with regulation 19(3)(e) of the MLRs. It thereby acted in breach of principles 6, 7 and 8 of the 2011 Principles; failed to achieve outcomes 7.2 and 7.5 of the SCC 2011; and acted in breach of principle 2 of the Principles and paragraphs 2.1(a) and 3.1 of the Code for Firms. 

From 26 June 2017 to 25 January 2024, it had failed to conduct client and matter risk assessments in compliance with the requirements of regulations 28(12)(a)(ii) and 28(13) of the MLRs, and had been unable to demonstrate appropriate compliance as required by regulation 28(16) of the MLRs. It has thereby acted in breach of principles 6, 7 and 8 of the 2011 Principles; failed to achieve outcomes 7.2 and 7.5 of the SCC 2011; and had acted in breach of principle 2 and paragraphs 2.1(a) and 3.1 of the Code for Firms. 

In respect of two specified files, the respondent had failed to conduct any or any adequate source of funds inquiries, contrary to regulation 28(11 to 13) of the MLRs; or to document the same, contrary to regulation 28(16) of the MLRs; and had thereby acted in breach of principle 2 and paragraphs 2.1(a) and 3.1 of the Code for Firms.

The parties had invited the SDT to deal with the allegations against the respondent in accordance with the statement of agreed facts and outcome annexed to the judgment. The SDT had reviewed all the material before it and was satisfied on the balance of probabilities that the respondent’s admissions had been properly made.

There was no evidence that any actual harm had been caused by any of the respondent’s admitted failures. However, its failure to comply with the MLRs 2017 over a lengthy period of time within the area of conveyancing, which is a higher risk sector of the MLR, had risked causing harm to the reputation of the legal profession.

The respondent had fully cooperated with the investigation and had taken active steps to remedy the admitted breaches. It had a previously unblemished regulatory record. 

A fine was the appropriate sanction. Considering the seriousness of the misconduct, the firm’s size, financial resources and revenue, a fine of £120,000 was proportionate in the circumstances. 

The respondent was ordered to pay costs of £25,290.

On 20 June 2025, the SRA intervened into CC Bell & Son, the recognised sole practice of Robin Edward Stubbings of 7 Grove Place, Bedford MK40 3JJ. The grounds of intervention were:

• It was necessary to intervene to protect the interests of clients or former clients and any beneficiaries of any trust of which Stubbings is or was a trustee (paragraph 1(1)(m) of Schedule 1 – Part I to the Solicitors Act 1974).
• Stubbings had failed to comply with any condition, subject to which his practising certificate was granted or otherwise has effect (paragraph 1(1)(l) of Schedule 1 – Part 1 to the Solicitors Act 1974).

Stubbings’ practising certificate was not suspended by reason of the intervention.

Richard Thorpe of Shakespeare Martineau, SHMA SRA Interventions, PO Box 18228, Birmingham B2 2HX (tel: 0300 247 2470; email: interventions@shma.co.uk) has been appointed to act as intervention agent.