The Respondent gave evidence and stated that at the time the declarations were made, he genuinely believed he had complied with the AML Regulations. In his interview with the SRA, he had readily accepted that he had not. He had not been dishonest. Thereafter he had taken steps to remedy the situation.

The Tribunal accepted that the Respondent had not been dishonest but found his conduct, amongst other things, to have been lacking in integrity and was reckless. Solicitors are expected to keep up to date with their regulatory and compliance obligations and to be proactive in seeking information and help to ensure they are not in breach. In this case the Tribunal found the Respondent to have been too sure of his compliance in the circumstances where he had not checked the rules and been unacceptably tardy in putting in place the necessary written AML policies and firm-wide risk assessment. He had also provided a banking facility to a client in the