Dennis Ko was fined and ordered to pay costs after AML breaches in a multi-million-dollar hotel deal.
A senior solicitor has been fined £27,500 and ordered to pay £25,000 in costs after admitting a string of anti-money laundering (AML) failings and allowing payments that carried the hallmarks of fraud.
Dennis Ko, admitted to the Roll in October 2002, was a partner at Kennedys Law LLP between May 2014 and September 2017. He acted as the matter partner in the purchase and subsequent sale of units in the Grosvenor Hotel, Bristol — a transaction that drew the attention of the Solicitors Regulation Authority (SRA).
Between 7 December 2016 and 22 September 2017, Ko failed to carry out adequate client due diligence and to perform ongoing monitoring of his client relationship. These lapses breached multiple provisions of the SRA Principles 2011, the SRA Code 2011, and the Money Laundering Regulations in both their 2007 and 2017 forms.
Embed from Getty ImagesThe tribunal heard that Ko’s failings caused the firm itself to breach key AML regulations, including those requiring identification and verification of clients, and ongoing scrutiny of transactions to ensure they were consistent with the client’s profile and business.
The case escalated when evidence showed that, between 23 May 2017 and 12 July 2017, Ko authorised or allowed a series of payments:
- Up to £925,000 to an individual named Mr Varma
- £10,000 to KD Law
- Up to £133,500 to Casa Investments Ltd
The SRA alleged — and Ko admitted — that these payments occurred in circumstances bearing the hallmarks of fraud, breaching Principle 6 of the SRA Principles and Rule 14.5 of the SRA Accounts Rules.
Although initial allegations also included breaches of Principle 2 (upholding public trust) and recklessness, these were withdrawn following Ko’s extensive admissions and a joint application by the parties to settle the matter by an agreed outcome.
In its findings, the Solicitors Disciplinary Tribunal (SDT) assessed the misconduct as very serious. The failures persisted over months and involved substantial sums, yet the tribunal determined that the misconduct did not warrant suspension or restrictions on Ko’s right to practise. Instead, a financial penalty was deemed proportionate.
Placing the matter within Indicative Fine Band Level 4, the tribunal approved the jointly proposed sanction: a £27,500 fine forfeited to the Crown, plus £25,000 in agreed costs.
In its written decision, the SDT stressed that solicitors have a professional duty to protect client funds from misuse and to act promptly when faced with potential indicators of fraud. It emphasised that failing to meet AML obligations exposes both clients and the wider public to significant financial risks.
For Ko, the ruling means a total financial hit of £52,500 and a public disciplinary record that will remain a matter of official record with the Law Society.
The case stands as another high-profile warning to solicitors involved in complex property or investment transactions: AML compliance is not optional, and ignoring red flags — even without proven dishonesty — can lead to severe professional and financial consequences.
