Keith R Thompson & Co
Craik Hill Chambers, Craik Hill Avenue, Immingham , DN40 1LP
Recognised sole practitioner
307692

Decision - Fined

Outcome: Fine

Outcome date: 14 May 2025

Published date: 30 May 2025

Firm details

Firm or organisation at time of matters giving rise to outcome

Name: Keith R Thompson & Co

Address(es): Craik Hill Chambers, Craik Hill Avenue, Immingham, DN40 1LP

Firm ID: 307692

Outcome details

This outcome was reached by SRA decision.

Decision details

1. Agreed outcome 

1.1 Keith R Thompson & Co (the Firm), a recognised sole practice authorised and regulated by the Solicitors Regulation Authority (SRA), agrees to the following outcome to the investigation:

1. Keith R Thompson & Co is fined £1,536, under Rule 3.1 
2. of the SRA Regulatory and Disciplinary Procedure Rules (the RDPRs) (b) to the publication of this agreement, under Rule 9.2 of the RDPRs 
3. Keith R Thompson & Co will pay the costs of the investigation of £600, under Rule 10.1 and Schedule 1 of the RDPRs. 

2. Summary of Facts

2.1 We carried out an investigation into the firm following an inspection by our AML Proactive Supervision team.

2.2 Our inspection identified areas of concern in relation to the firm's compliance with the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017 (MLRs 2017), the SRA Principles 2011, the SRA Code of Conduct 2011, the SRA Principles 2019 and the SRA Code of Conduct for Firms 2019.

3. Allegation

3.1 Between 26 June 2017 and 14 February 2025, the firm failed to sufficiently assess the level of client and matter risk, as required by Regulation 28(12) and Regulation 28(13) of the MLRs 2017.

4. Admissions

4.1 The firm admits, and the SRA accepts, that by failing to comply with the MLRs 2017, that it breached, for conduct up to 24 November 2019 (when the SRA Handbook 2011 was in force):

1. Principle 6 of the SRA Principles 2011 – which states you must behave in a way that maintains the trust the public places in you and in the provisions of legal services. 
2. Principle 8 of the SRA Principles 2011 – which states you must run in your business or carry out your role in the business effectively and in accordance with proper governance and sound financial risk management principles.

and the firm failed to achieve: 

3. Outcome 7.2 of the SRA Code of Conduct 2011 – which states you have effective systems and controls in place to achieve and comply with all the Principles, rules and outcomes and other requirements of the Handbook, where applicable. 
4. Outcome 7.5 of the SRA Code of Conduct 2011 – which states you comply with legislation applicable to your business, including anti-money laundering and data protection legislation.

and from 25 November 2019 (when the SRA Standards and Regulations came into force) until 14 February 2025, the firm breached: 

5. Principle 2 of the SRA Principles 2019 – which states you act in a way that upholds public trust and confidence in the solicitors' profession and in legal services provided by authorised persons. 
6. Paragraph 2.1(a) of the SRA Code of Conduct for Firms 2019 – which states you have effective governance structures, arrangements, systems and controls in place that ensure you comply with all the SRA's regulatory arrangements, as well as with other regulatory and legislative requirements, which apply to you. 
7. Paragraph 3.1 of the SRA Code of Conduct for Firms 2019 – which states that you keep up to date with and follow the law and regulation governing the way you work. 

5. Why a fine is an appropriate outcome

5.1 The SRA's Enforcement Strategy sets out its approach to the use of its enforcement powers where there has been a failure to meet its standards or requirements.

5.2 When considering the appropriate sanctions and controls in this matter, the SRA has taken into account the admissions made by the firm and the following mitigation:

1. There is no evidence of harm to consumers, or third parties, and our view is that the risk of repetition is low. 
2. The firm took steps to rectify its failures and has since implemented a fully compliant CMRA process. 
3. The firm has cooperated with the SRA's AML Proactive Supervision and AML Investigations teams.
4. The firm has admitted the breaches and shown remorse. 

5.3 The SRA considers that a fine is the appropriate outcome because:

1. The conduct showed a disregard for statutory and regulatory obligations and had the potential to cause harm, by facilitating dubious transactions that could have led to money laundering (and/or terrorist financing). This could have been avoided had the firm conducted and documented appropriate risk assessments on its clients and files, on in-scope matters.  
2. It was incumbent on the firm to meet the requirements set out in the MLRs 2017. The firm failed to do so. The public would expect a firm of solicitors to comply with its legal and regulatory obligations, to protect against these risks as a bare minimum.  
3. The agreed outcome is a proportionate outcome in the public interest because it creates a credible deterrent to others and the issuing of such a sanction signifies the risk to the public, and the legal sector, that arises when solicitors do not comply with anti-money laundering legislation and their professional regulatory rules.  

5.4 Rule 4.1 of the Regulatory and Disciplinary Procedure Rules states that a financial penalty may be appropriate to maintain professional standards and uphold public confidence in the solicitors' profession and in legal services provided by authorised persons. There is nothing within this Agreement which conflicts with Rule 4.1 of the Regulatory and Disciplinary Rules and on that basis, a financial penalty is appropriate. 

6. Amount of the fine

6.1 The amount of the fine has been calculated in line with the SRA's published guidance on its approach to setting an appropriate financial penalty (the Guidance).

6.2 Having regard to the Guidance, the SRA and the firm agree that the nature of the misconduct was more serious (score of three). This is because the firm should have been aware of its obligation to complete CMRAs. The firm undertakes significant amount of work in scope of the MLRs 2017. The firm has failed to follow published guidance, such as the Legal Sector Affinity Group guidance, and pay sufficient regard to the SRA's warning notice and guidance on CMRAs, first published on 18 October 2023.

6.3 Although the firm put in place a CMRA process, following the SRA's desk-based review, both client risk and matter risk were not being adequately assessed for a significant period of time following the introduction of the MLRs 2017.

6.4 The SRA considers that the impact of harm or risk of harm is assessed as being low (score of two). This is because there is no evidence of any harm being caused as a result of the firm not completing client and matter risk assessments. There is no evidence that the lack of CMRAs caused the firm to fail to identify its high-risk clients or apply the correct level of due diligence on matters, despite being obliged to complete CMRAs pursuant to the MLRs 2017.

6.5 The nature and impact scores add up to five. This places the penalty in Band "B", as directed by the guidance.

6.6 Since February 2025, the firm has confirmed it put in place measures to ensure continuing and future compliance, reviewed all live in-scope files and ensured the necessary documentation has been placed on them. Despite its current compliance, it failed to do this for a period of several years. The lack of client and matter risk assessments on files, over this period, shows a pattern of behaviour and increases the risks of the firm laundering illicit funds. The SRA, therefore, considers a basic penalty in the higher end of the bracket to be appropriate.

6.7 Based on the evidence the firm has provided of its annual domestic turnover for the most recent tax year, this results in a basic penalty of £1,919. 

6.8 The SRA considers that the basic penalty should be reduced to £1,536. This reduction reflets the mitigation set out in paragraph 5.2 above.

6.9 The firm does not appear to have made any financial gain or received any other benefit as a result of its conduct. Therefore, no adjustment is necessary and the financial penalty is £1,536. 

7. Publication

7.1 Rule 9.2 of the SRA Regulatory and Disciplinary Procedure Rules states that any decision under Rule 3.1 or 3.2, including a Financial Penalty, shall be published unless the particular circumstances outweigh the public interest in publication.  

7.2 The SRA considers it appropriate that this agreement is published as there are no circumstances that outweigh the public interest in publication and it is in the interest of transparency in the regulatory and disciplinary process.  

8. Acting in a way which is inconsistent with this agreement

8.1 The firm agrees that it will not deny the admissions made in this agreement or act in any way which is inconsistent with it.

8.2 If the firm denies the admissions or acts in a way which is inconsistent with this agreement, the conduct which is subject to this agreement may be considered further by the SRA. That may result in a disciplinary outcome or a referral to the Solicitors Disciplinary Tribunal on the original facts and allegations.

8.3 Acting in a way which is inconsistent with this agreement may also constitute a separate breach of principles 2 and 5 of the Principles and paragraph 3.2 of the Code of Conduct for Firms. 

9. Costs

9.1 The firm agrees to pay the costs of the SRA's investigation in the sum of £600. Such costs are due within 28 days of a statement of costs due being issued by the SRA. The date of this Agreement is 14 May 2025.