Robert Simon & Co fined £7,847 and ordered to pay £600 costs for AML compliance breaches
Robert Simon & Co, a recognised sole practice in Shoreham-by-Sea, has been fined for repeated breaches of anti-money laundering (AML) regulations. The Solicitors Regulation Authority (SRA) imposed a financial penalty of £7,847 and ordered the firm to pay £600 in investigation costs.
The SRA began its investigation after the firm was selected for an AML inspection by its Proactive Supervision team. When notified of the inspection, the firm admitted that it lacked a documented and compliant AML control environment, prompting the inspection to be cancelled and a full investigation launched.
The investigation found that between June 2017 and October 2024, Robert Simon & Co failed to produce a firm-wide risk assessment (FWRA) required under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017). Firms are required to document the risks of money laundering and terrorist financing across five key areas, but the practice did not have a compliant assessment in place until October 2024.
The firm also failed to establish and maintain policies, controls and procedures (PCPs) to manage those risks, as required by Regulation 19 of the MLRs. Effective PCPs are fundamental to ensuring that a practice can identify and mitigate potential money laundering risks. Robert Simon & Co only produced compliant PCPs after October 2024.
Embed from Getty ImagesFurther, from June 2017 until February 2025, the firm did not maintain proper client and matter risk assessments (CMRAs) as required under Regulation 28. This meant it could not demonstrate that its measures were proportionate or appropriately documented. The firm has since implemented a compliant CMRA template and now applies it to its files.
By failing to comply with these requirements, the firm admitted breaching SRA Principles 6 and 8 of the 2011 framework, alongside Outcomes 7.2 and 7.5 of the Code of Conduct 2011. From November 2019 onwards, it breached Principle 2 of the SRA Principles 2019, as well as paragraphs 2.1(a) and 3.1 of the Code of Conduct for Firms 2019.
The SRA said the misconduct was serious because it persisted over several years despite regulatory obligations being clear and longstanding. The failings formed a pattern of misconduct and exposed the firm to risks that could have facilitated money laundering or terrorist financing.
Although no evidence of actual harm was found, the SRA assessed the risk as medium due to the absence of effective systems for such a long period. It added that the failures “showed a disregard towards statutory and regulatory obligations” and “could have been avoided had the firm established adequate AML documentation and controls”.
In mitigation, Robert Simon & Co made early admissions, informed the regulator of its shortcomings before inspection, and has since put in place a compliant FWRA, PCPs, and CMRA processes. The firm also cooperated fully with the investigation.
The initial penalty was calculated at £8,719, but reduced to £7,847 to reflect cooperation and remediation. The regulator confirmed that the firm had not profited from the breaches.
The agreement requires the firm not to deny its admissions or act inconsistently with them. If it does, the matter may be referred to the Solicitors Disciplinary Tribunal.
The decision was published on 22 September 2025.