Key Details:
Firm: Scott-Moncrieff & Associates (ScoMo) – a virtual law firm run by former Law Society president Lucy Scott-Moncrieff
Fine: £68,000 (plus £1,350 costs)
Main Breach:
- Allowed $23m to pass through client account with no underlying legal work
- Firm provided escrow services for a Russian client purchasing an asset from a Canadian company for $22.5m
- Received $23.3m in three payments and distributed: $22.5m to supplier, $525k to client’s German agent, and $262.5k to an Estonian company
- The SRA determined this constituted using the client account as an improper banking facility
Additional AML Failures:
- 2022 SRA inspection found none of the firm’s AML compliance was adequate:
- Firm-wide risk assessments
- Policies, controls and procedures (PCPs)
- Matter risk assessments
- Ongoing monitoring
- Customer due diligence
- All were non-compliant with 2017 Money Laundering Regulations
- 2023 follow-up inspection found PCPs still non-compliant despite previous guidance
Regulatory Context:
- SRA could exceed the standard £25,000 fine limit because the firm is an Alternative Business Structure (can fine up to £250m)
- Fine calculated at 2% of turnover
- Consultant solicitor Ian Insley also fined £9,941 (27% of annual income) plus £1,350 costs for “wilful or reckless disregard”
Current Status:
- Firm has appealed to the Solicitors Disciplinary Tribunal (SDT)
- Awaiting written reasons for SDT’s rejection of appeal
- Scott-Moncrieff indicated they may appeal the SDT decision
Risk Assessment: SRA cited the risk that the client account “may have been used for money laundering, terrorist financing or other illegal or improper purposes”
This case is particularly significant given Lucy Scott-Moncrieff’s prominent standing (2012-13 Law Society president, current judge in Court of Protection and Mental Health Tribunal).