Mulcahy Smith Limited (Mulcahy Smith)
23 Regent Terrance, Gateshead , NE8 1LU
Recognised body
640868

Decision - Fined

Outcome: Fine

Outcome date: 18 June 2026

Published date: 23 July 2026

Firm details

No detail provided:

Outcome details

This outcome was reached by SRA decision.

Decision details

Who does this disciplinary decision relate to?

Mulcahy Smith Limited, located at 23 Regent Terrace, Gateshead, NE8 1LU, a recognised body (the firm).

Short summary of decision

We have fined the firm for breaches of its obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLRs).

Facts of the misconduct

In March 2025 the SRA undertook an AML desk based review at the firm. It identified deficiencies in the firm’s policies, controls and procedures (PCPs) and the firm’s process for carrying out client and matter risk assessments. Findings

It was found as follows.

Allegation 1

Between 26 June 2017 and 8 July 2025, the firm failed to establish and maintain fully compliant policies, controls, and procedures (PCPs) to mitigate and effectively manage the risks of money laundering and terrorist financing identified in any risk assessment (FWRA), pursuant to regulation 19(1)(a) of the MLRs, and regularly review and update them pursuant to regulation 19(1)(b) of the MLRs.

In doing so, to the extent the conduct took place between 1 July 2013 and 24 November 2019 the firm breached outcomes 7.2 and 7.5 of the SRA Code of Conduct 2011 and Principles 6 and 8 of the SRA Principles 2011. To the extent that the conduct took place from 25 November 2019 onwards the firm breached paragraphs 2.1(a) and 3.1 of the Code of Conduct for Firms and Principle 2 of the SRA Principles 2019.

Allegation 2

10 In four of the six files reviewed, the firm failed to maintain records of its risk assessment under regulation 28 of the MLRs. Therefore, the firm was unable to demonstrate that the extent of the measures it had taken to satisfy the requirements of regulation 28 was appropriate, as required by regulation 28(16) of the MLRs.

In doing so the firm breached paragraphs 2.1(a) and 3.1 of the Code of Conduct for Firms and Principle 2 of the SRA Principles 2019.

Decision on sanction

The firm was directed to pay a financial penalty of £2,137 and ordered to pay costs of £1,350.

It was decided that a financial penalty was an appropriate and proportionate sanction.

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

• it involved a failure of the firm’s systems and controls
• The failure to have compliant PCPs persisted for a long period
• The conduct had the potential to cause significant harm
• The firm had responsibility for its own conduct

In view of the above, the firm’s conduct was placed in conduct band B, which has a financial penalty bracket of between 0.4 % and 1.2%. The penalty was placed at the bottom of this bracket, at B1. This reflects the fact that while the firm’s conduct gave rise to a risk of harm, no actual harm resulted and the firm took prompt steps to address the deficiencies which the SRA had identified.

The financial penalty was reduced by 30% to recognise that the firm made early admissions of the breaches, co-operated fully with the SRA and brought itself into compliance promptly.

SRA Principles breached

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

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.

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

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