John P Martin & Co fined £3,340 for failing to carry out proper anti-money laundering checks
John P Martin & Co, a recognised law firm based in Scarborough, has been fined £3,340 following an investigation by the Solicitors Regulation Authority (SRA). The fine comes after the firm was found to have failed to comply with anti-money laundering (AML) regulations, specifically the Money Laundering, Terrorist Financing, and Transfer of Funds Regulations 2017 (MLRs 2017).
The SRA’s investigation followed a desk-based review by its AML Proactive Supervision Team, which identified significant gaps in the firm’s compliance processes. Between 26 June 2017 and 31 January 2025, the firm failed to conduct a documented firm-wide risk assessment (FWRA) of the money laundering and terrorist financing risks to which its business was subject, as required under the MLRs 2017.
John P Martin & Co admitted to the breach and has agreed to a regulatory settlement, which includes the fine and the payment of £600 towards the costs of the investigation. The firm has also taken steps to rectify the situation, including reviewing and amending its risk assessment procedures to ensure compliance with the relevant AML legislation.
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The SRA’s review found that the firm had failed to properly assess and address the risks of money laundering, particularly in the context of its conveyancing work. This failure left the firm vulnerable to potential misuse for illicit financial activities. The firm’s conduct was deemed a disregard for statutory obligations, and the SRA noted that such breaches could have exposed the public to significant harm.
The fine was calculated based on the SRA’s guidelines, taking into account the severity of the misconduct, the firm’s cooperation with the investigation, and the steps it has taken to improve its processes. The SRA also highlighted the firm’s failure to act on previous warning notices about its obligation to have a compliant FWRA in place since 2017.
While there was no evidence of financial gain or direct harm to clients or third parties, the SRA emphasised that the firm’s failure to maintain a robust anti-money laundering control environment put it at greater risk of being exploited for illegal activities.
John P Martin & Co has committed to continuing to improve its AML procedures, including providing training to its fee earners on source of funds and source of wealth checks. The firm’s updated processes are now in line with the requirements of the MLRs 2017, and it is expected to maintain rigorous controls moving forward.
The SRA has stated that the fine, while relatively modest, serves as a deterrent to other firms and underscores the importance of compliance with AML regulations within the legal sector.