Leadenhall Law Group Ltd
The Union Building, Level 3, 51-59 Rose Lane, Norwich , NR1 1BY
Recognised body
443007

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 24 July 2026

Published date: 27 July 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by agreement.

Decision details

1.1 Leadenhall Law Group Limited, a licensed body since 5 June 2023 (previously a recognised body) agrees to the following outcome to the investigation of its conduct by the Solicitors Regulation Authority (SRA):

1. it is fined £16,092
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 March 2017 and January 2020, Leadenhall Law Group Limited (the firm) acted for a non-domestic politically exposed person (PEP), and their associated companies across 14 matters.

2.2 The matters consisted of residential property purchase transactions. All proceeded to completion.

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 14(4) of the MLRs 2007 and Regulation 33(5) of the MLRs 2017 are similar and require a relevant person, i.e. 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 received information obtained by the firm in respect of the PEP and their finances. The SRA identified that the firm did not have the systems in place to adequately identify the client as a PEP or establish the PEPs source of funds/wealth.

3. Admissions

3.1 Leadenhall Law Group Limited makes the following admissions which the SRA accepts:

Between March 2017 and January 2020, as exemplified in respect of client matters linked to a non-domestic PEP, the firm failed adequately or at all to have effective policies, controls and procedures in place to:

1. identify the beneficial owner of its client as a PEP.
2. take adequate measures to establish the source of wealth and/or source of funds involved in those transactions.

And in doing so, the firm failed to meet the requirements of:

1. Regulations 14(4)(b) of the MLRs 2007;
2. Regulation 35(1) of the MLRs 2017; and
3. Regulation 28(11) and/or 35(5)(b) of the MLRs 2017.

By failing to comply with the MLRs 2007 and 2017 it has failed to:

From March 2017 to 25 November 2019 (when the SRA Handbook 2011 was in force)

1. achieve Outcome 7.2 of the SRA Code of Conduct 2011, which requires that they 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.
2. achieve Outcome 7.5 of the SRA Code of Conduct 2011 which requires that they comply with legislation applicable to your business, including anti-money laundering and data protection legislation.
3. behave in in a way that maintains the trust the public places in them and in the provision of legal services in breach of Principle 6 of the SRA Principles 2011.
4. run their business effectively and in accordance with proper governance and sound financial and risk management principles in breach of Principle 8 of the SRA Principles 2011.

From 25 November 2019 onwards (when the SRA Standards and Regulations came into force)

5. comply with all of the SRA's regulatory arrangements, as well as with other regulatory and legislative requirements in breach of Paragraph 2.1(a) of the SRA Code of Conduct for Firms.
6. keep up to date with and follow the law and regulation governing the way it works in breach of Paragraph 3.1 of the SRA Code of Conduct for Firms.
7. act in a way that upholds public trust and confidence in the solicitors' profession and in legal services provided by authorised persons in breach of Principle 2 of the SRA Principles.

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:

• The obligation was on the firm to comply with the MLRs 2007 and 2017. The firm is responsible for ensuring it meets its obligations and had direct responsibility for its own conduct.
• It is in the public interest that firms ensure compliance with the MLRs 2007 and 2017. 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 conducted, this mitigates and manages the risk and ensures that the public can take comfort that firms are complying with their legal and regulatory obligations.
• 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. 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 28 and 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 did not identify its client as a PEP but did recognise the high-risk nature of the client. Despite this, 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 is appropriate.

5.5 The basic penalty is £17,880.

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

• The firm has cooperated with our investigation
• The firm has ensured that it is now compliant, and will remain compliant with the MLRs 2017

5.7 Following the discount adjustment for mitigation, the basic penalty is £16,092.

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.

Decision - Sanction

Outcome: Rebuke

Outcome date: 26 October 2023

Published date: 1 November 2023

Firm details

No detail provided:

Outcome details

This outcome was reached by SRA decision.

Decision details

1. Agreed outcome

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

1. it is rebuked
2. to the publication of this agreement
3. it will pay the costs of the investigation of £300.

2. Summary of Facts

2.1 The client instructed the Firm in connection with the purchase of a residential property in London. The Firm were also instructed to assist with a lease extension. However, the Firm acted for both the seller and buyer in this transaction and the client states they were not aware of this and terminated the retainer in March 2022.

2.2 The Firm confirmed that it acted for both parties, and it did consider if conflict could occur. The Firm stated that no negotiations were due to take place, due to the property being sold at auction, and it had sufficient safeguards in place.

2.3 The Firm explained that 2 offices each handled a separate side of the sale – the seller's solicitor was situated in the Norwich office, and the buyer's solicitor was situated in the London office. Each office used separate and different case management systems; therefore, in their view, there was no risk of contamination or the fee earners acting on each side of the transaction being able to view the other party's file.

2.4 The Firm stated that the client must have been aware it acted for both parties, as it was stated in literature provided to them. However, they admit that the client never specifically agreed to this, but that they believe the client would have agreed had they asked them.

2.5 Paragraph 6.2 of the SRA Code of Conduct for Firms states that it is a requirement for firms to have obtained informed consent from both clients, but only if the firm had first satisfied itself that there was an exception applicable that allowed it to act for two or more clients in the same matter.

2.6 The Firm considered it had the necessary safeguards in place and considered it reasonable to act for both parties, however informed consent was not obtained from the client.

2.7 The Firm, who assumed that the client was aware and would have consented to the Firm acting for both clients, did not consider the need for informed consent being required.

3. Admissions

3.1 The Firm makes the following admissions, which the SRA accepts:

1. they have failed to act in the client’s best interests and, therefore, have breached Principle 7 of the SRA Principles 2019, which states:
   'You act in the best interests of each client.'
2. they acted where there was either an actual or a significant risk of a conflict of interest between two clients and did not receive informed consent from the client and, therefore, have breached Paragraph 6.2 of the SRA Code of Conduct for Firms, which states:
   'You do not act in relation to a matter or particular aspect of it if you have a conflict of interest or a significant risk of such a conflict in relation to that matter or aspect of it, unless:
   1. the clients have a substantially common interest in relation to the matter or the aspect of it, as appropriate; or
   2. the clients are competing for the same objective, and the conditions below are met, namely that:
      1. all the clients have given informed consent, given or evidenced in writing, to you acting;
      2. where appropriate, you put in place effective safeguards to protect your clients' confidential information; and
      3. you are satisfied it is reasonable for you to act for all the clients.'

4. Why a written rebuke 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 When considering the appropriate sanctions and controls in this matter, the SRA has taken into account the admissions made by the Firm and the following mitigation which it has put forward:

1. the Firm have since changed their policy and will no longer act for both buyer and seller in a property transaction
2. the Firm did refer to SRA guidance and considered it had sufficient safeguards in place to enable it to act for both parties and
3. the Firm have cooperated fully with our investigation.

4.3 The SRA considers that a written rebuke is the appropriate outcome because:

1. the Firm did not obtain informed consent from the client, despite there being a requirement to obtain informed consent from all clients involved in a transaction
2. they had direct control and responsibility for their conduct
3. a public sanction is required to uphold public trust and confidence in the delivery of legal services by SRA regulated firms.

5. Publication

5.1 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.

6. Acting in a way which is inconsistent with this agreement

6.1 The Firm agrees that it will not deny the admissions made in this agreement or act in any way which is inconsistent with it.

6.2 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.

6.3 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.

7. Costs

7.1 The Firm agrees to pay the costs of the SRA's investigation in the sum of £300. Such costs are due within 28 days of a statement of costs due being issued by the SRA.