AML: Solicitor did not know what a FWRA was
A sole practitioner has been struck off for ignoring the anti-money laundering (AML) rules for six years and also showing a “complete disregard” for residual client balances.
The Solicitors Disciplinary Tribunal (SDT) said William Joseph Harris’s “widespread and fundamental non-compliance with critical regulations represented systemic failures throughout the six years of his sole practice”.
The 71-year-old qualified in 1980 and ran William Harris Solicitors in Lancaster between 2018 and 2024, when the Solicitors Regulation Authority (SRA) shut it down. He conducted mainly conveyancing and probate work.
According to a statement of agreed facts and outcome approved by the SDT, the regulator became involved in 2023 after Mr Harris submitted overdue qualified accountant’s reports that highlighted significant breaches of the accounts rules and AML weaknesses.
In admitting his misconduct, Mr Harris said he had “struggled” as a sole practitioner.
In December 2019, he completed a declaration to the SRA that a firm-wide risk assessment was in place – but, when interviewed by the SRA four years later, confessed that he did not know what one was. He admitted the declaration had been dishonest and lacked integrity.
The SDT described this as “a very serious example of dishonesty given his position as a solicitor and COLP, in a high-risk area, and in response to a direct regulatory inquiry.”
During that time, Mr Harris failed to ensure the firm had either an assessment or the required AML policies, controls and procedures in place.
Between 1 January 2022 and 30 September 2023, he did not conduct adequate customer due diligence or source of funds checks in relation to 63 conveyancing clients, representing £8.8m worth of transactions.
Mr Harris accepted that he had shown a “casual disregard” for the formal requirements of customer due diligence and did not “scratch beneath the surface of what was presented to him”.
The SDT noted: “The firm’s vulnerability to money laundering and terrorist financing, underscored by £8.8m in unverified funds, posed a direct threat to the integrity of the legal profession and public safety.”
Shortly before the firm was shut down, it had 54 residual client balances totalling £102,000. Mr Harris accepted that he had shown a “complete disregard” of the need to return client money throughout the existence of the firm.
His failure to distribute monies after undertaking probate meant some beneficiaries did not receive their entitlements for years, while some had passed away before they did.
He did not obtain accountant’s reports for the 2020/21 and 2021/22 years until October 2022 – beyond the six-month deadline – and then took eight months to send them on to the SRA. He did not obtain one at all for 2022/23.
Striking off Mr Harris was “the only reasonable and proportionate sanction to mark the seriousness of the misconduct, protect the public and maintain the reputation of the profession”, the SDT concluded.
It also ordered that he pay costs of almost £30,000.
Anonymous solicitor 
He is of an age where we didn’t have all this excessive AML nonsense. Before these times many Solicitors did operate a common sense approach. If something seemed suspicious, or a client seemed a crook, just don’t act.