High-profile firm fined after breaching conduct rules and money laundering regulations in an agreed outcome
One of the world’s most prominent law firms, Simpson Thacher & Bartlett LLP, has been fined after admitting to breaches of professional conduct rules and money laundering regulations.
The case, brought by the Solicitors Regulation Authority (SRA), was concluded by way of an Agreed Outcome, meaning the firm accepted the regulator’s findings without a contested hearing before the Solicitors Disciplinary Tribunal (SDT).
The allegations centred on breaches of the SRA Code of Conduct 2011, the SRA Code of Conduct for Firms 2019, the Money Laundering Regulations, and both the SRA Principles 2011 and SRA Principles 2019. While the specific details of the misconduct were not disclosed in the brief summary, the nature of the charges makes clear they related to serious compliance failures in the handling of client matters.
Money laundering regulations impose strict obligations on law firms to ensure they do not facilitate or become complicit in the movement of illicit funds. These requirements include rigorous client due diligence, proper record-keeping, and the identification and reporting of suspicious activity. Breaches can undermine the integrity of the legal profession and expose the financial system to criminal abuse.
Embed from Getty ImagesBy admitting to breaches under both the older 2011 rules and the newer 2019 regulations, Simpson Thacher & Bartlett’s case spans a period of evolving compliance standards in the legal sector. The SRA has repeatedly warned firms that failures in anti-money laundering (AML) procedures will be treated with the utmost seriousness, given the reputational and systemic risks involved.
The use of an Agreed Outcome means the firm accepted responsibility for the misconduct and the sanction imposed without the need for a full tribunal hearing. This route often results in a more streamlined resolution but still carries the weight of formal findings. The fine imposed serves both as a penalty and as a deterrent to other firms who might fall short of regulatory expectations.
Simpson Thacher & Bartlett LLP is a global law firm with a prestigious client base and operations in key financial centres. That stature makes the case a stark warning: no firm, however large or well-regarded, is immune from regulatory scrutiny or sanction.
The SRA’s decision reinforces its message that all firms must ensure robust systems and controls are in place to comply with conduct and AML rules. High-value transactions, complex cross-border matters, and influential clients can heighten the risk profile — making meticulous compliance not just a legal requirement, but a professional necessity.
The regulator has been steadily increasing its enforcement activity in this area, with law firms across the sector facing fines for similar breaches. The legal industry’s position as a potential gateway for money laundering means regulators expect nothing less than total adherence to preventative measures.
While the financial penalty for Simpson Thacher & Bartlett LLP was not detailed in the brief, the case adds to a growing list of enforcement actions against top-tier firms. It underscores the SRA’s determination to hold even the most established players accountable when they fall short of the rules.
For clients and the wider public, the case is a reminder that regulation in the legal sector is active and robust. For law firms, it is yet another cautionary tale: compliance lapses — particularly those involving money laundering regulations — will be met with swift and public sanction, regardless of reputation or market standing.
