SRA fines Jeremy Bennett for using the client account as a banking facility and AML breaches
Jeremy Michael Bennett, a former solicitor and owner of 7 Legal and Finance Limited, has been fined £4,273 by the Solicitors Regulation Authority (SRA) after an investigation found that the firm’s client account was used to transfer £9.1 million without proper records or compliance checks.
The regulatory settlement agreement, published on 3 November 2025, followed an investigation into concerns raised in January 2024 by Pennine Law Limited, where Mr Bennett was then working as a consultant. The report alleged that Mr Bennett and his firm had transferred approximately £9.1 million in 2022 without client instruction, prompting concerns over potential breaches of the SRA Accounts Rules and anti-money laundering regulations.
According to the SRA’s findings, the funds were received into 7 Legal and Finance’s client account from the beneficiaries of a trust between 28 November and 6 December 2022. The money was subsequently dispersed to two third parties on instructions from the trustee, Mr M, but the beneficiaries denied authorising the transfers or having access to the funds afterwards.
The investigation found no corresponding client ledger for the transactions and determined that Mr Bennett failed to maintain accurate financial records as required under Rule 8.1(a) of the SRA Accounts Rules. The SRA said the absence of proper accounting controls meant the firm’s client account was used “as a banking facility”, contrary to Rule 3.3.
The SRA noted that solicitors are prohibited from using client accounts in this way because such transfers may lend legitimacy to financial movements that could conceal unlawful activity.
The regulator also found that Mr Bennett failed to carry out adequate due diligence under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017). No written client and matter risk assessment was recorded for the transaction, and Mr Bennett admitted that his assessment was “kept as a mental note”.
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The SRA identified multiple high-risk indicators in the matter, including the use of complex trust structures, overseas accounts, and funds originating from Hong Kong, Dubai, Panama, and the British Virgin Islands. Despite these red flags, there was no evidence that Mr Bennett had undertaken or documented enhanced due diligence or source of funds checks, as required by Regulations 28 and 33 of the MLRs 2017.
In the interview, Mr Bennett acknowledged that the transaction was “high risk” for the firm and fell outside its usual scope of work. He admitted that he did not know the origin of the beneficiaries’ funds, despite a schedule of assets indicating substantial offshore holdings and cryptocurrency investments.
The SRA concluded that Mr Bennett’s failures amounted to breaches of Principle 2 of the SRA Principles, requiring solicitors to uphold public trust and confidence and Paragraph 7.1 of the Code of Conduct for Solicitors, which mandates compliance with all relevant laws and regulations.
While the regulator recognised that Mr Bennett had no prior disciplinary record, cooperated fully, and is no longer practising, it determined that a fine was necessary to uphold professional standards. The SRA said: “Mr Bennett facilitated a high-risk transaction without considering the potential risks. This resulted in £9.1m of unclear origin flowing through the firm’s client account.”
The fine was reduced from a base calculation of £5,028 to £4,273, reflecting mitigating factors, and Mr Bennett was ordered to pay £600 towards investigation costs. The SRA said publication of the decision was mandatory under Section 87 of the Legal Services Act 2007.
Mr Bennett agreed to the outcome and accepted the findings. The SRA noted that any denial of the admissions made under the agreement could result in further disciplinary action or referral to the Solicitors Disciplinary Tribunal.