Tolhurst Fisher fined £120k after tribunal finds systemic AML failings over more than a decade
Tolhurst Fisher LLP has been fined £120,000 and ordered to pay £25,290 in costs after admitting a series of anti‑money laundering (AML) failings spanning more than 15 years. The Solicitors Disciplinary Tribunal (SDT) approved the penalty on 17 April 2025, following an agreed outcome between the Solicitors Regulation Authority (SRA) and the long‑established firm. The breaches, which the Tribunal described as “very serious” and placed in its highest fine band, covered two separate sets of Money Laundering Regulations.
The case arose from a desk‑based AML review in October 2023, initiated after the firm completed an SRA questionnaire. The review revealed multiple shortcomings in the firm’s compliance framework, including the absence of a firm‑wide risk assessment for over two years, inadequate policies and procedures, and failures to carry out basic client and matter risk assessments. In some instances, key documents lacked detail on geographic risks, client base, and the nature of products and services. The Tribunal found that from June 2017 until November 2019, the firm had no firm‑wide risk assessment at all, despite clear statutory requirements. Even after such a document was introduced, it remained inadequate until January 2024.
Embed from Getty ImagesBetween December 2007 and December 2012, the firm had no appropriate, risk‑sensitive policies or procedures to address AML risks, as required under the 2007 regulations. When policies were eventually introduced, they still fell short of requirements, failing to address high‑risk transactions, unusual patterns, or transactions without a lawful purpose. Under the 2017 regulations, the firm’s policies, controls, and procedures were again found lacking. They omitted detail on politically exposed persons, complex transactions, ongoing monitoring, and the application of enhanced due diligence. The firm also failed to update these documents despite new guidance being issued by the SRA and the Legal Sector Affinity Group.
From June 2017 to January 2024, the firm did not conduct adequate client and matter risk assessments, meaning it could not demonstrate compliance with the relevant regulations. The Tribunal also examined two specific client files and found no, or inadequate, source‑of‑funds checks. In one case, a €270,000 property purchase was entirely funded by the client without proper inquiry. In another, a business acquisition involved personal savings, family loans, and a third‑party investment, but the firm failed to gather or document evidence to determine whether enhanced due diligence was needed.
The Tribunal concluded that the misconduct spanned more than a decade, involved repeated breaches of fundamental statutory requirements, and occurred in a firm heavily engaged in conveyancing—a sector considered high‑risk for money laundering. Although there was no evidence of actual money laundering, the absence of adequate checks meant the possibility could not be ruled out. The Tribunal found that the firm knew, or ought reasonably to have known, it was in material breach of obligations designed to protect the public and the profession’s reputation. Aggravating factors included the prolonged duration of the breaches and the scale of the work undertaken in high‑risk areas. Mitigating factors were the firm’s cooperation with the investigation, early admissions of misconduct, and remedial action taken to address deficiencies.
The £120,000 fine was deemed proportionate, reflecting the seriousness of the misconduct, the size of the firm, and its financial resources. The agreed costs of £25,290 were also approved as reasonable. In its ruling, the Tribunal underlined the importance of rigorous AML compliance as a critical defence against serious crime and warned that failures of this scale severely undermine trust in the legal profession
