Scott-Moncrieff and Associates Limited (Scott-Moncrieff and Associates Limited)
Temple Chambers, 3-7 Temple Avenue, London , EC4Y 0HP
Licenced body
596379

Decision - Fined

Outcome: Fine

Outcome date: 12 August 2025

Published date: 2 February 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by SRA decision.

Decision details

Who does this disciplinary decision relate to?

Scott-Moncrieff and Associates Limited (the firm), is a licensed body with offices at Temple Chambers, Suite 244, 3-7 Temple Avenue, London.

Summary of Decision

The firm was fined for failing to ensure it had relevant documentation in place to prevent activities relating to money laundering and terrorist financing as required by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017).

Also, for allowing payments into and out of its client account in one client matter which were other than in respect of the delivery of legal services, resulting in its client account being used to provide banking facilities.

Facts of the misconduct

On 28 June 2022, the SRA’s Anti-Money Laundering (AML) Proactive Team carried out an inspection at the firm. This identified that the firm’s firm-wide risk assessment (FWRA), policies controls and procedures (PCPs), matter risk assessments, ongoing monitoring and customer due diligence (CDD) were not compliant with the MLRs 2017.

On 23 August 2022, the SRA’s AML regulatory manager recommended that the firm should immediately address his concerns and provided the firm with guidance to support it in doing so. He notified the firm that following the SRA’s inspection, because of its serious failure to comply with the MLRs 2017, he had referred the matter to the SRA’s AML investigation team for formal investigation.

In July 2023, the SRA began a forensic investigation at the firm. This identified that a consultant at the firm acted for a client located in the Russian Federation in relation to its purchase of an asset for $22,500,000 from a company located in Canada. The firm agreed to provide escrow services and general advice to the client. It did not act in the sale and purchase agreement for the asset and there was no need for it to receive or make payments relating to that underlying transaction.

However, between 17 March and 10 August 2021, the firm received three sums into its client bank account totalling $23,287,470.07 from its client.

Between 15 April and 28 May 2021, the firm made three payments totalling $22,499,990.13 to the company supplying the asset to its client. On the client’s instructions the firm paid $525,000 to the client’s agent located in Germany and $262,438.46 to another company located in Estonia.

On 3 October 2023, the SRA began an investigation into the firm. The investigation officer notified the firm that its AML documentation was not compliant with the MLRs 2017 and did not incorporate the guidance provided by the SRA’s AML regulatory manager on 23 August 2022. As at 30 September 2022, the firm’s FWRA was largely compliant with the MLRs 2017. The firm’s PCPs were not fully compliant.

It was found that the firm failed:

Allegation 1 (a)

1. Between 26 June 2017 and October 2021, to have in place a documented assessment of the risks of money laundering and terrorist financing to which its business was subject (a firm-wide risk assessment (FWRA) pursuant to Regulation 18(1) and 18(4) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017).

Allegation 1 (b)

2. From October 2021 to October 2022, to have in place a FWRA that identified and assessed the risks of money laundering to which it was subject taking into account all risk factors pursuant to Regulation 18(2) of the MLRs 2017;

Allegation 1 (c)

3. From 26 June 2017 onwards, to establish and maintain policies, controls and procedures (PCPs) to mitigate and effectively manage the risks of money laundering and terrorist financing, identified in any risk assessment pursuant to Regulation 19(1)(a) of the MLRs 2017, and regularly review and update them pursuant to Regulation 19(1)(b) of the MLRs 2017.

   In doing so, to the extent the conduct took place between 11 October 2011 and 24 November 2019, the firm:

   1. breached Principles 6 and 8 of the SRA Principles 2011 (2011 Principles)
   2. failed to achieve Outcomes 7.2 and 7.5 of the SRA Code of Conduct 2011 (2011 Code of Conduct) and to the extent the conduct took place from 25 November 2019, the firm breached:
   3. Principle 2 of the SRA Principles 2019 (2019 Principles)
   4. Paragraphs 2.1(a) and 3.1 of the SRA Code of Conduct for Firms 2019 (Code of Conduct for Firms).

Allegation 2

4. Between 17 October 2020 and 22 October 2021, the firm allowed payments into and out of its client account, any or all of which were other than in respect of the delivery of regulated services, resulting in its client account being used to provide banking facilities. In doing so the firm breached:
   1. Rule 3.3 of the SRA Accounts Rules 2019
   2. Principle 2 of the 2019 Principles

Decision on sanction

The firm was directed to pay a financial penalty of £68,000 and ordered to pay costs of £1,350.

This was because the firm’s conduct was serious by reference to the following factors in the SRA Enforcement Strategy:

1. The findings included breaches of the MLRs 2017, which protect the public from the serious consequences of money laundering and terrorist financing.
2. The firm allowed a substantial sum to be processed through its client account when there was no proper connection between the legal services it provided and the payments it was asked to make and receive in breach of the SRA Accounts Rules 2019. This also gave rise to the serious risk that its client account may have been used for money laundering, terrorist financing or other illegal or improper purposes.
3. Its conduct was a breach of its regulatory obligations which persisted for longer than was reasonable.
4. The firm was responsible for its own conduct which was serious and had the potential to cause harm to the public interest and to public confidence in the legal profession.

In view of the above, the firm’s conduct was placed in conduct band C which has a financial penalty of 1.6 per cent to 3.2 per cent of annual domestic turnover. The firm’s conduct was placed in the lower range of this band at C2 (2 per cent of annual domestic turnover).

SRA Standards and Regulations breached

SRA Principles 2011

Principle 6 You must behave in a way that maintains the trust the public places in you and in the provision of legal services.

Principle 8 You must run your business or carry out your role in the business effectively and in accordance with proper governance and sound financial and risk management principles.

SRA Principles 2019

Principle 2 You act in a way that upholds public trust and confidence in the solicitors' profession and in legal services provided by authorised persons. SRA Accounts Rules 2019

Rule 3.3 You must not use a client account to provide banking facilities to clients or third parties. Payments into, and transfers or withdrawals from a client account must be in respect of the delivery by you of regulated services.

SRA Code of Conduct 2011

Outcome 7.2 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.

Outcome 7.5 You comply with legislation applicable to your business, including anti-money laundering and data protection legislation.

SRA Code of Conduct for Firms 2019

Paragraph 2.1(a) 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.

Paragraph 3.1 You keep up to date with and follow the law and regulation governing the way you work.