• Application 11703-2017
• Admitted 2006
• Hearing 3 January 2018
• Reasons 9 January 2018
The SDT ordered that the respondent should pay a fine of £25,000, and that he should be subject to the following restriction orders: that he might not: be a compliance officer for legal practice or a compliance officer for finance and administration; be a sole signatory to client account; have the power to solely authorise electronic transfers from a client account; and be a recognised sole practitioner, manager or owner of an authorised body; with liberty to either party to apply to the SDT to vary those conditions.
The matter was dealt with by way of the agreed outcome procedure.
The respondent had provided a banking facility to his client S, through his client account. He had received payments into and made transfers into and out of his client account which were not made in respect of instructions relating to an underlying transaction (and the funds arising therefrom) or to a service forming part of his normal regulated activities, in breach of rule 14.5 of the SRA Accounts Rules 2011 and principle 6 of the SRA Principles 2011.
In acting for his client, S, he had failed to have sufficient regard for his duties under the Money Laundering Regulations 2007 and the SRA’s warning notice on money laundering and terrorist financing, in breach of all or any of principles 6, 7 and 8 and outcome 7.5 of the SRA Handbook. He had acted recklessly.
Taking into account the factual background of the case and the allegations made and admitted, the SDT had determined that the proposed sanction was appropriate.
The respondent was ordered to pay costs of £6,220.