Dean Wilson LLP
Ridgeland House, 165 Dyke Road, Brighton , BN3 1TL
Recognised body
532989

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 11 August 2026

Published date: 17 August 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

1.1 Dean Wilson LLP (the firm), a recognised body agrees to the following outcome to the investigation of its conduct by the Solicitors Regulation Authority (SRA):

• it is fined £25,000
• to the publication of this agreement
• it will pay the costs of the investigation of £600.

2. Summary of Facts

2.1 We carried out an anti-money laundering desk-based review at the firm to assess its compliance with the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017 (MLRs 2017).

2.2 This review identified areas of concern in relation to the firm’s compliance with the 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.

2.3 Between 26 June 2017 and March 2023, the firm failed to maintain fully compliant policies, controls and procedures (PCPs), pursuant to Regulation 19(1)(a) of the MLRs 2017.

2.4 When the Investigation Officer conducted a review of the firm’s PCPs for the period prior to April 2023, to understand the effectiveness of what was in place she found that they do not cover (or failed to sufficiently detail) the following requirements:

• Mitigation of Money Laundering / Terrorist Financing (ML/TF) risk involving new products, practices or technologies.
• Provision to identify and scrutinise complex transactions.
• Provision to identify and scrutinise unusually large or unusual patterns of transactions.
• Provision to identify and scrutinise transactions that have no apparent economic or legal purpose.
• The taking of additional measures, where appropriate, to prevent the use for money laundering or terrorist financing of products and transactions which might favour anonymity.
• High-risk jurisdictions / High risk third countries (as of 10 January 2020).
• Reporting discrepancies to Companies House (as of 10 January 2020).

2.5 After July 2019, the firm’s PCPs were not updated until 2023. In that time, vital guidance was issued enabling firms to know what to include its PCPs which would keep the firm up to date and its AML controls strong.

2.6 As part of the desk-based review which concluded in July 2024, we reviewed a copy of the firm’s Regulation 19 PCPs, that had been in place since April 2023. Guidance was provided to the firm on how these PCPs needed to be improved. Following engagement between the firm and the SRA we are satisfied that with some further development; these PCPs satisfied the requirements of the MLRs 2017.

2.7 Between 26 June 2017 and 26 September 2024, the firm failed to have in place compliant client and/or matter risk assessments in relation to client files, as required by Regulation 28(12) and Regulation 28(13) of the MLRs 2017.

2.8 The desk-based review identified that only one of the eight files reviewed had a CMRA present. This was, however, not fully completed by the fee earner in question.

2.9 The CMRA form which the firm was previously using was assessed as non-compliant. This is because it did not consider Regulation 28(13(b) and (c) of the MLRs 2017. The firm was reminded that the purpose of carrying out a CMRA is to identify and inform which level of due diligence should be applied, and that this included taking into account high risk indicators set out under Regulation 33 of the MLRs 2017, such as whether the client is a PEP or where a client or counterparty is based in a high-risk third country (HRTC). The previous CMRA form did not consider any money laundering or terrorist financing risks such as these, nor did it allow the fee earner to record the level of risk or due diligence to be applied to a particular client or matter.

2.10 The firm was asked to make amendments to its CMRA and also document a CMRA on all live in-scope files by 4 October 2024. The firm sent us its updated CMRA on 27 September 2024. The CMRA was split into two separate forms which was a client risk assessment form and a matter risk assessment form. The firm also later confirmed that training in relation to its new CMRA was completed on 18 October 2024.

2.11 The firm has confirmed, and we are satisfied, that it completes client and matter risk assessments on all live in-scope files as part of its standard file-opening procedures, and that it continues to address its historic backlog of legacy files. We are satisfied the firm is taking appropriate and proportionate steps in this regard.

3. Admissions

3.1 The firm has breached Regulations 19(1)(a) and 28(12) and 28(13) of the MLRs 2017. Additionally, in light of those breaches, the firm accepts that:

From June 2017 to 25 November 2019 (when the SRA Handbook 2011 was in force), it has failed to:

1. achieve Outcome 7.2 of the SRA Code of Conduct 2011, which requires that they 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.
2. achieve Outcome 7.5 of the SRA Code of Conduct 2011 which requires that they comply with legislation applicable to your business, including anti-money laundering and data protection legislation.
3. behave in in a way that maintains the trust the public places in them and in the provision of legal services in breach of Principle 6 of the SRA Principles 2011.
4. run their business effectively and in accordance with proper governance and sound financial and risk management principles in breach of Principle 8 of the SRA Principles 2011.

From 25 November 2019 onwards (when the SRA Standards and Regulations came into force), it has failed to:

5. comply with all of the SRA’s regulatory arrangements, as well as with other regulatory and legislative requirements in breach of Paragraph 2.1(a) of the SRA Code of Conduct for Firms.
6. keep up to date with and follow the law and regulation governing the way it works in breach of Paragraph 3.1 of the SRA Code of Conduct for Firms.
7. act in a way that upholds public trust and confidence in the solicitors' profession and in legal services provided by authorised persons in breach of Principle 2 of the SRA Principles.

4. Why a fine is an appropriate outcome

4.1 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.

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

• PCPs are fundamental in setting out a firm’s approach to practical AML and Counter Terrorist Financing activities. They should be effective in identifying and mitigating risks within its practice and play an important role in managing the risk of a firm facilitating money laundering and/or terrorist financing.
• All firms within scope of the MLRs 2017 are required to have PCPs in place that mitigate and effectively manage the risks of money laundering and terrorist financing. Between 26 June 2017 and March 2023, the firm failed to maintain fully compliant policies, controls and procedures. The firm therefore did not have effective arrangements in place to manage compliance with the money laundering regulations for nearly six years. This is a serious failing which left the firm vulnerable to being used to facilitate dubious transactions, that could have led to money laundering and/or terrorist financing. The SRA’s investigation found that no such conduct occurred, as detailed at paragraph 5.3.
• It was in the public interest for the firm to ensure compliance with money laundering legislation. The firm’s failure to do so diminishes the trust the public placed in it and the delivery of legal services.
• Taking a risk-based approach to preventing money laundering is important because it helps firms to direct resources appropriately to the highest risk areas. Firms need to understand and assess the risk posed by each client and matter – then act accordingly.
• CMRAs dictate the level and extent of customer due diligence to be completed on a client or matter. Where the correct due diligence has been applied to clients and their matters, the risk of money laundering is reduced.
• All eight files failed to meet the requirements of the MLRs 2017 as they did not contain effective CMRAs. The number of files found to be not compliant (all of them) shows that, for many years, the firm did not have effective arrangements and procedures to ensure compliance with money laundering regulations. This left the firm vulnerable to the risks of money laundering, particularly when acting in conveyancing transactions, which have been highlighted as high-risk areas of work in the Government’s National Risk Assessments and our Sectoral Risk Assessments.

4.3 A fine is appropriate to maintain professional standards and uphold public confidence in the solicitors' profession. A financial penalty therefore meets the requirements of rule 4.1 of the Regulatory and Disciplinary Procedure Rules.

5. Amount of the fine

5.1 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).

5.2 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 a pattern was identified across the files demonstrating that the requirements of Regulation 19 and 28 of the MLRs 2017 were not met.

5.3 The SRA considers that the impact of the misconduct was low (score of two). There is no evidence of any actual harm being caused by the deficiencies identified. This is also mitigated by the fact that the firm did have some measures in place to assist in the prevention of money laundering. For example, the firm was making attempts to keep on top of its firm wide AML controls by implementing a firm-wide risk assessment and updating its policies, controls and procedures

5.4 The nature and impact scores add up to five. The Guidance indicates a broad penalty bracket of between 0.4% and 1.2% of the firm’s annual domestic turnover is appropriate.

5.5 The basic penalty is £30,965.

5.6 The SRA and the firm agree that the basic penalty should be reduced to account for the following mitigating factors:

• the firm has cooperated with the AML Proactive and Investigation teams.
• the firm is taking steps to remedy the harm

5.7 The SRA considers that the basic penalty should be reduced to £25,000. This reduction reflects the mitigation set out above and the SRA’s discretion permitted in the Guidance.

5.8 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 to remove this and the amount of the fine is £25,000.

6. Publication

6.1 The SRA considers it appropriate that this agreement is published in the interests of transparency in the regulatory and disciplinary process. The firm agrees to the publication of this agreement.

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

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

7.2 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.

7.3 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.

8. Costs

8.1 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.