Southend-based law firm Tolhurst Fisher LLP was slapped with a £120,000 fine, with additional costs of £25,290, for failing to implement a firm-wide AML risk assessment over a period spanning more than 15 years.
The Solicitors Disciplinary Tribunal (SDT) concluded that between June 2017 and January 2024, Tolhurst Fisher had failed to “conduct or have in place” a proper risk assessment. According to the SDT’s report, the firm also neglected “appropriate steps to identify and assess the risks of money laundering and terrorist funding.”
“Despite…warnings, the misconduct complained of continued and included periods when the firm had no, as opposed to no adequate, appropriate safeguards in place as required by the regulations.” — SDT report, May 2025
Importantly, no actual instances of money laundering or client losses were uncovered. However, the Tribunal emphasised the risk to the public and to public confidence in the legal profession posed by such prolonged non-compliance.
A wake up call for law firms
The managing partner of Tolhurst Fisher, Mark Francis, acknowledged the seriousness of the matter:
“The anti-money laundering policy and procedure breaches on our part are wholly regrettable. We understand the importance of the principles behind the regulations and our part in ensuring that the important role the legal profession plays in preventing money laundering is upheld.”
Francis also noted the firm’s remedial efforts, which included hiring an external consultant, implementing a new management structure, introducing firmwide AML training, and overhauling policies and procedures. The SRA has since confirmed that the firm’s updated AML controls are compliant.
“AML compliance is a fundamental part of the operation of this firm, and we have learned a great deal since the initial SRA investigation. We would encourage other firms to do likewise.”
Cooperation and remedial action softened the blow
Tolhurst Fisher LLP’s proactive response to the Solicitors Regulation Authority’s (SRA) investigation played a significant role in mitigating the severity of the sanctions imposed. The Solicitors Disciplinary Tribunal recognised these efforts, noting that the firm’s cooperation and prompt remedial actions were mitigating factors in determining the penalty. According to the SDT’s Guidance Note on Sanctions, such cooperation and early admissions can lead to reduced sanctions, as they demonstrate genuine insight and a commitment to compliance.
How to avoid the same mistake
For legal professionals and compliance officers, this case reinforces three key lessons:
- Risk assessments aren’t optional. AML regulations require documented, firm-wide risk assessments. Failing to conduct one is a breach in itself, even if no money laundering occurs.
- Warnings matter. Repeated failures to act after SRA warnings escalated the seriousness of the case.
- Remedial action is critical. Cooperation and swift improvements can mitigate reputational and regulatory damage, and even the financial penalty.
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