Decisions and interventions

The Solicitors Disciplinary Tribunal ordered that the respondent, a recognised body, should pay a fine of £58,000.

From 26 June 2017 until 27 April 2022, the respondent had failed to have a firm-wide risk assessment in place which complied with the requirements of regulation 18 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information of the Payer) Regulations 2017 (MLRs). It had 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), and 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.

From 26 June 2017 until April 2022, it had failed to have policies, controls and procedures (PCPs) in place which complied with the requirements of regulation 19(1)(a) of the MLRs; to regularly review and update its PCPs in compliance with regulation 19(1)(b) of the MLRs, or to monitor and manage compliance with its PCPs in compliance with regulation 19(3)(e) of the MLRs. It had thereby acted in breach of principles 6, 7 and 8 of the Principles 2011; had failed to achieve outcomes 7.2 and 7.5 of the SCC 2011; and had 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 until April 2022, 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, thereby acting in breach of any or all of principles 6, 7 and 8 of the Principles 2011, and failing to achieve any or all of 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.

Between 26 June 2017 and January 2024, it had failed to establish an independent audit in compliance with the requirements of regulation 21(1)(c) of the MLRs and had thereby acted in breach of principles 6, 7 and 8 of the Principles 2011, and failed to achieve outcomes 7.2 and 7.5 of the SCC 2011; and in breach of principle 2 of the Principles and paragraphs 2.1(a) and 3.1 of the Code for Firms.

The respondent had admitted each of the allegations made against it by the SRA.

The parties had invited the tribunal to deal with the allegations against the respondent in accordance with a statement of agreed facts and outcome annexed to the judgment. The parties submitted that the outcome proposed was consistent with the SDT’s guidance note on sanctions.

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.

The misconduct had been very serious. There seemed to have been no reason why the respondent had not followed the regulations, and the lack of compliance had persisted for a long time.

Compliance with the anti-money laundering regulations was required as being a key method of potentially disrupting serious crime.

The proposed fine of £58,000 was appropriate and proportionate in all the circumstances.

The respondent was ordered to pay costs of £20,000.

The SDT ordered that the respondent should be struck off the roll.

While in practice as a solicitor at Bawtrees LLP, the respondent had, between approximately 30 June 2022 and 1 July 2022, given misleading information to G of The Wilkes Partnership, by informing her that he was in receipt of client A’s deposit in connection with the purchase of a property and that he would transfer client A’s deposit to TWP by 4 July 2022, when he knew that he had not received client A’s deposit. He had thereby breached principles 2 and 5 of the SRA Principles 2019, and paragraph 1.4 of the Code of Conduct for Solicitors, RELs and RFLS 2019. He had acted recklessly.

The respondent had failed to perform an undertaking that he had given to G that by 4 July 2024 he would transfer client A’s deposit from Bawtrees to TWP and send client A’s copy of the exchanged contract to TWP, thereby breaching principle 2 of the Principles and paragraph 1.3 of the code.

On 16 September 2022, he had attempted to prevent L of TWP or client B from providing information to the SRA about the conduct referenced in the above allegations, thereby breaching principles 2 and 5, and paragraph 7.5 of the code.

Central to the admitted misconduct was a property transaction for a very high-value property, in the region of £6m with a £650,000 deposit. The respondent had acted for the purchaser. The allegations were interconnected. They concerned a breach of an undertaking in the conveyancing transaction and recklessness.

The respondent’s culpability was total. He had chosen not to follow the well-established rules. The admitted conduct was very serious, involving as it did two episodes of lack of integrity coupled with recklessness.

The misconduct had involved a serious lack of integrity at a very high level on two separate occasions, demonstrating a pattern of behaviour and a troubling mindset on the respondent’s part. He had failed to self-report the misconduct and instead had taken active steps to prevent the conduct being reported to the SRA.

In the circumstances of the case, the protection of the public, public confidence in the profession and the reputation of the profession required no lesser sanction than that the respondent be removed from the roll.

There was no order for costs.

The SDT ordered that the respondent should be struck off the roll.

While in practice as a solicitor, in connection with Client A, between June and July 2022, the respondent had provided misleading information to the Employment Tribunal (ET), thereby breaching principles 2, 4 and 5 of the SRA Principles 2019, and paragraph 1.4 of the Code of Conduct for Solicitors 2019.

Following a wasted costs order made by the ET on 9 September 2022 (which the respondent had not opposed), the respondent had misled Client A in January 2023, thereby breaching principles 2, 4 and 5, and paragraph 1.4 of the Code of Conduct.

The respondent had agreed to a settlement offer from the defendant on 21 December 2022 and had withdrawn Client A’s claim on 3 January 2023 without Client A’s instructions or knowledge, thereby breaching principles 2, 4, 5 and 7, and paragraphs 1.4 and 3.1 of the code.

Between December 2022 and January 2023, the respondent had misled Client A by falsely stating that his ET hearing, listed for 3-6 January 2023, had been adjourned due to a lack of available ET staff, thereby breaching principles 2, 4 and 5, and paragraph 1.4 of the code.

On 13 September 2021, the respondent had misled Client B by stating there was ‘an offer on the table’ regarding her employment dispute, when no settlement offer had been made by the opposing party, thereby breaching principles 2, 4 and 5, and paragraph 1.4 of the code.

On 12 September 2022, the respondent had misled Client C by stating that his case was listed ‘for March of next year’ when it had not been listed, thereby breaching principles 2, 4 and 5, and paragraph 1.4 of the code.

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.

The misconduct had involved serious, deliberate and repeated acts of dishonesty, misleading both clients and the ET over a period of time. As an experienced solicitor, the respondent had direct control over her actions, which had caused significant harm to the clients, preventing them from pursuing their claims.

Despite mitigating factors such as her previously exemplary record and health issues, the case did not fall within the ‘small residual category’ where striking off would be a disproportionate sanction. Therefore, the SDT accepted that strike-off was the most proportionate sanction to protect the public and maintain the reputation of the profession.

The respondent was ordered to pay costs of £12,000.

The SDT ordered that the respondent should be suspended from practice as a solicitor for 12 months from 3 July 2025. Upon the expiry of that fixed term of suspension, the respondent should be subject to conditions imposed by the SDT as follows: that she might not (i) practise as a sole practitioner or sole manager or sole owner of an authorised or recognised body, or as a freelance solicitor, or as a solicitor in an unregulated organisation; (ii) be a partner or member of a limited liability partnership, legal disciplinary practice or alternative business structure or other authorised or recognised body; (iii) be a head of legal practice/compliance officer for legal practice or a head of finance and administration/compliance officer for finance and administration; (iv) hold client money; (v) be a signatory on any client account; or (vi) work as a solicitor other than in employment approved by the SRA, with liberty to either party to apply to the SDT to vary the conditions set out above.

While in practice as a solicitor and sole practitioner at Rowe Radcliffe, between 25 November 2019 and 30 September 2021, the respondent had caused or allowed a shortage on the client account to occur and had failed to replace that shortage promptly. She had thereby breached principles 2 and 5 of the SRA Principles 2019; rules 5.1, 5.3 and 6.1 of the SRA Accounts Rules; and paragraph 4.2 of the SRA Code of Conduct for Solicitors, RELs and RFLs.

Between 25 November 2019 and 23 March 2023, she had failed to keep and maintain accurate and/or contemporaneous and/or compliant account records, thereby breaching principle 2 of the Principles, and rule 8.1 of the accounts rules.

Between 25 November 2019 and 31 August 2021, she had failed to complete reconciliations for all client accounts held or operated by the firm at least every five weeks, thereby breaching rule 8.3 of the accounts rules.

Between 21 June 2021 and 23 March 2023, she had failed adequately to engage and cooperate with the SRA and to respond to the Legal Ombudsman in relation to ongoing investigations, thereby breaching principles 2 and 5 of the Principles, and paragraphs 7.3 and 7.4 of the code for solicitors.

The parties had invited the SDT to deal with the allegations against the respondent in accordance with a 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.

The respondent’s level of culpability was high. Harm had been caused to the reputation of the profession. The misconduct had continued over a significant period of time and an allegation of lack of integrity had been found proved. The respondent had made early admissions and had cited the impact of her health on her ability to operate the firm, which the SDT had taken into consideration. She had now retired.

A suspension for a period of one year, along with practising conditions that would take effect after the period of suspension had concluded, represented an appropriate and proportionate sanction that was commensurate to the misconduct admitted by the respondent and found proved by the SDT.

There had been no application for costs.

On 4 September 2025, an Adjudication Panel resolved to intervene into the practice of Shafqat Ali, including but not limited to his practice at SK Lloyds Solicitors Ltd, and into SK Lloyds Solicitors Ltd itself from premises based at Office 1, Newsham House, 103 Manchester Road, Bury BL9 0TD. The intervention was effected on 10 September 2025.

The grounds of intervention into the practice of Ali were:

(i) There was reason to suspect dishonesty on Ali’s part in connection with his practice as a solicitor (paragraph 1(1)(a)(i) of Schedule 1 – Part I to the Solicitors Act 1974).

(ii) Ali had failed to comply with rules (paragraph 1(1)(c) of Schedule 1 – Part I to the Solicitors Act 1974).

The grounds for intervention into SK Lloyds Solicitors Ltd were:

(i) There was reason to suspect dishonesty on the part of Ali, as a manager of the firm, in connection with the firm’s business (paragraph 32(1)(d)(i) of Schedule 2 to the Administration of Justice Act 1985).

(ii) Ali, as a manager of the firm, and the firm itself, have failed to comply with the SRA Principles 2011 and 2019 [and the SRA Accounts Rules 2011 and 2019] which are rules applicable to them both by virtue of section 9 of the Administration of Justice Act 1985 (paragraph 32(1)(a) of Schedule 2 to that act).

Sean Joyce of Stephensons Solicitors LLP, Wigan Investment Centre, Waterside Drive, Wigan WN3 5BA (tel: 0333 321 4408; email: interventions@stephensons.co.uk) has been appointed to act as the Society’s agent.