City Law Firm Limited (St John Legal)
Winchester House, 19 Bedford Row, London , WC1R 4EB
Recognised body
537440

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 23 June 2026

Published date: 25 June 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

1. Agreed outcome

1.1 City Law Firm Limited, a recognised body agrees to the following outcome to the investigation of its conduct by the Solicitors Regulation Authority (SRA):

1. it is fined £13,684
2. to the publication of this agreement
3. it will pay the costs of the investigation of £600

2. Summary of Facts

2.1 Between June 2021 and December 2023, City Law Firm Limited which trades as St John Legal (the firm), acted for a non-domestic politically exposed person (PEP), and their associated companies across 66 matters.

2.2 The matters consisted of residential property purchases and refinancing work.

2.3 The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017) require relevant persons to apply enhanced checks when acting for a PEP.

2.4 The measures set out in Regulation 35(5) of the MLRs 2017 require a relevant person, the firm, to:

1. have approval from senior management for establishing or continuing the business relationship with that person;
2. take adequate measures to establish the source of wealth (SoW) and source of funds (SoF) which are involved in the proposed business relationship or transactions with that person; and
3. where the business relationship is entered into, conduct enhanced ongoing monitoring of the business relationship with that person.

2.5 As part of an SRA investigation, we reviewed the information obtained by the firm in respect of the PEP and their finances. The SRA identified that the firm had not taken adequate measures to establish the source of wealth and source of funds in its transactions with that PEP.

3. Admissions

3.1 City Law Firm Limited makes the following admissions which the SRA accepts:

In respect of its client, a non-domestic PEP, and matters linked to that client, between June 2021 and December 2023 the firm failed to take adequate measures to establish the source of wealth and source of funds involved.

By failing to comply with the MLRs 2017 it has breached:

1. Principle 2 of the SRA Principles – 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.
2. Paragraph 2.1(a) of the SRA Code of Conduct for Firms – 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.
3. Paragraph 3.1 of the SRA Code of Conduct for Firms – which states that you keep up to date with and follow the law and regulation governing the way you work.

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:

1. The obligation was on the firm to comply with the money laundering regulations. The firm is directly responsible for ensuring it meets its obligations and had direct responsibility for its own conduct.
2. It is in the public interest that firms ensure compliance with the money laundering regulations. A failure to do so has the potential to cause significant harm by exposing the firm to the risk that its services will be used to carry out money laundering or terrorist financing. Where thorough checks are carried out, this mitigates and manages the risk and ensures that the public can take comfort that firms are complying with their legal and regulatory obligations.
3. The firm's conduct was serious, and diminished trust in the legal profession. Any lesser sanction would not provide a credible deterrent to the Firm and others.

A credible deterrent plays a key role in maintaining professional standards and upholding public confidence.

4.3 A fine is appropriate to maintain professional standards and uphold public confidence in the solicitors' profession and in legal services provided by authorised persons. 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 35 of the MLRs 2017 were not met.

5.3 The SRA considers that the impact of the misconduct was medium (score of four). PEPs are high risk clients (holding positions of power and influence, making it easier to obtain funds via corruption or by stripping assets of their country of origin) and the measures as set out in the money laundering regulations specifically have sections dedicated to PEPs requiring additional scrutiny to be applied to mitigate the increased risk. The firm identified its client as a PEP at the outset and took action to mitigate the risk by applying enhanced customer due diligence measures and obtaining senior management approval. However, in practice, the required actions as specified in the money laundering regulations were not adequately executed.

5.4 The nature and impact scores add up to seven (Band C). The Guidance indicates a broad penalty bracket of between 1.6% and 3.2% of the Firm's annual domestic turnover.

5.5 Based on the firm’s annual domestic turnover, the basic penalty is £17,105.

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

1. The firm made early admissions, recognising where it went wrong and why.
2. The firm has worked extensively to take the appropriate remedial action, including the implementation of new processes and additional training.
3. The firm has fully co-operated with the SRA throughout its investigation.

Following the discount adjustment for mitigation, the basic penalty is £13,684.

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.