Harrison Thames Valley Solicitors LLP, a recognised law firm based at 7 Castle Street, Reading, RG1 7SB, has been fined £25,000 by the Solicitors Regulation Authority (SRA) following serious breaches of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017).
The SRA decision, published on 14th January 2025, highlights that between 26th June 2017 and 2nd November 2023, the firm failed to maintain appropriate measures to assess and mitigate risks related to money laundering and terrorist financing.
An investigation by the SRA’s Anti Money Laundering (AML) team found that:
- The firm did not have an adequate firm-wide risk assessment (FWRA) to identify and assess money laundering risks in compliance with Regulation 18 of the MLRs 2017.
- It lacked fully compliant Policies, Controls, and Procedures (PCPs) to manage those risks, contravening Regulation 19(1)(a) and 19(1)(b) of the MLRs 2017.
These deficiencies breached:
- SRA Principles 2011, including Principles 6 and 8, and Outcomes 7.2 and 7.5 of the SRA Code of Conduct 2011.
- SRA Principles 2019, including Principle 2, and relevant provisions of the SRA Code of Conduct for Firms 2019.
Sanctions and Mitigating Factors
The firm’s conduct was deemed serious under the SRA’s Enforcement Strategy due to its potential to harm public trust and confidence in the legal profession. However, the penalty was mitigated because:
- The firm cooperated fully with the investigation.
- It promptly addressed the breaches and implemented compliant AML documentation by 2 November 2023.
- No actual harm to clients or third parties was identified.
The £25,000 fine was calculated as 1.6% of the firm’s annual domestic turnover, placing the conduct in the lower range of Band C penalties. The firm was also ordered to pay £1,350 in costs.
Harrison Thames Valley Solicitors LLP has since demonstrated full compliance with the MLRs 2017 and affirmed its commitment to maintaining effective risk management systems.