James Counsell KC represents the SRA in Solicitors Disciplinary Tribunal proceedings against a US law firm for breaches of AML regulations

James Counsell KC recently acted on behalf of the Solicitors Regulatory Authority, successfully prosecuting Simpson Thacher & Bartlett for failing to have anti-money laundering (AML) risk assessments and procedures in place in its London office. A fine of £300,000 was issued by the regulatory body.

The SRA identified various issues during a routine review of Simpson Thacher & Bartlett in 2021 and referred the matter to the Solicitors Disciplinary Tribunal (SDT) in November 2023, instructing James Counsell KC to act on its behalf.

Simpson Thacher admitted its failure to comply with AML regulations between June 2017 and 2023 including:

• Firm-Wide Risk Assessment: Between June 2017 and March 2020, the firm did not have a compliant risk assessment covering the entire practice, as required under the Money Laundering Regulations 2017.
• Client and Matter Risk Assessments: From June 2017 to October 2022, the firm failed to conduct appropriate risk assessments for individual clients and matters.
• Policies, Controls, and Procedures: Between June 2017 and January 2023, the firm lacked fully compliant AML policies and procedures, increasing the risk of potential money laundering activities.

The firm was compliant by the time the SRA referred it in November 2023.

At the hearing on 12th March 2025, the SDT approved a fine, agreed between the parties, of £300,000. James also secured £62,000 towards the SRA’s legal costs from Simpson Thacher.

Press Coverage

This case has been covered widely by the press and can be viewed below:

• Legal Futures – London office of top US firm fined £300k for AML failures
• Reuters – Law firm Simpson Thacher agrees to UK fine over money laundering rule breaches
• Financial Times – Simpson Thacher fined £362,000 over anti-money laundering failures

Find out more

James Counsell KC has a longstanding background in regulatory and disciplinary work. His practice spans the whole range of regulatory work both for and against professionals, including appearing in hearings involving accountants, solicitors, barristers, IFAs and actuaries. He is regularly instructed by the BSB and the SRA and he has acted for Lloyd’s of London in nearly 40 cases.

To find out more, contact Paul Barton on +44 (0)207 427 4907 or Lexie Johnson on + 44 (0) 207 427 0801 for a confidential discussion.

News 18 Mar, 2025