Strike-offs, six-figure fines and SLAPPS: the SDT’s 2025 year in review

Having represented solicitors and firms in SRA investigations for many years, I know firsthand how devastating these proceedings can be professionally, financially and personally. While many investigations are resolved at the SRA stage, the most serious cases reach the Solicitors Disciplinary Tribunal (SDT), which has the power to fine, suspend or strike solicitors from the roll.

The decisions handed down in 2025 offer crucial lessons for every practitioner. Here are eight takeaways shaping how lawyers approach compliance, client care and professional conduct in 2026.

1. Solicitors acting in good faith on proper instructions will not be held responsible for their client’s later-discovered wrongdoing

In December 2025, the SDT summarily dismissed the SRA’s test case against Carter-Ruck partner Claire Gill over an alleged strategic lawsuit against public participation (SLAPP). Gill had sent a letter in April 2017 while acting for Dr Ignatova, the “crypto queen” behind OneCoin, which was later discovered to be fraudulent.

The Tribunal said the case was based on hindsight rather than evidence of professional misconduct. While it is now known that OneCoin was a fraudulent enterprise, that was not apparent at the relevant time. It found that Gill’s advice was measured, professional and conscientious, describing her as a solicitor acting in good faith and on instructions.

The decision was the second setback in a week for the SRA’s clampdown on so-called SLAPPs. In a case shrouded in secrecy, Christopher Harding, a partner at London firm Hamlins, was also cleared by the SDT of any misconduct in relation to a SLAPP allegation.

These decisions indicate that solicitors acting in good faith on proper instructions will not face retrospective regulatory sanction based on facts that emerge years later. While reassuring, particularly for defamation and reputation management practitioners, they also underline the importance of keeping detailed contemporaneous file notes of instructions received, advice given and assessments made at the time.

• Anti-money laundering failures are now attracting six-figure fines, and the High Court has confirmed “strict liability”

2025 has seen some eye-watering fines. Simpson Thacher & Bartlett LLP was fined £300,000 for having no firm-wide risk assessment, non-compliant policies, controls and procedures, and missing client and matter risk assessments on four files over a significant period. Tolhurst Fisher LLP received a £120,000 fine for prolonged firm-wide risk assessment failures, policies and procedures failures and inadequate source-of-funds checks. Huggins Lewis Foskett was fined £58,000 for “very serious” AML breaches, including firm-wide risk assessment failures and failing to carry out an independent audit.

The High Court in SRA v Dentons UK and Middle East LLP confirmed that proving a breach of the Money Laundering Regulations suffices to establish a breach of the SRA’s requirement to comply with legal and regulatory obligations, without any need for a separate misconduct assessment.

• A document labelled AML “policy” or “risk assessment” is not enough, content and upkeep matter

It is vital that every firm has an up-to-date firm-wide risk assessment addressing geography, clients, products and services, and delivery channels, supported by robust policies and procedures. These must deal properly with PEP treatment, scrutiny of complex or unusual transactions, ongoing monitoring, enhanced due diligence triggers, third-party reliance, client and matter risk assessments, high-risk jurisdictions and Companies House discrepancy reporting.

The SDT is looking for evidence of genuine, tailored risk assessment and active governance, not box-ticking. Generic or outdated templates will fail, as demonstrated by Simpson Thacher, Tolhurst Fisher and Huggins Lewis Foskett. While fines are scaled to firm size and resources, prolonged failures (particularly in conveyancing) will be treated as “very serious”. The strict liability principle means no excuses.

• Dishonesty almost invariably leads to strike-off, but there are narrow exceptions

Several solicitors were struck off for dishonesty in 2025. William Harris was struck off after dishonestly confirming to the SRA that his firm had a compliant firm-wide risk assessment when it did not. His conduct was compounded by serious AML and Accounts Rules breaches. Belinda Sarkodie was struck off for dishonestly submitting overlapping timesheets to two locum firms while employed full-time elsewhere, and for misleading her primary employer. Alexander Campbell was struck off despite mental health mitigation, where the dishonesty involved fabricated academic and prize claims and misleading references.

However, 2025 also saw cases where a finding of dishonesty did not result in strike-off. In Roberts, a solicitor dishonestly deleted emails to conceal her involvement in supervising amendments to Particulars of Claim. The SDT imposed a 12-month suspension, finding the case fell within the “small residual category” where strike-off was disproportionate. It emphasised that a single dishonest act did not make the respondent a dishonest person.

In Goodwin, a junior solicitor dishonestly edited an email address in a forwarded chain to conceal an error. The Tribunal found exceptional circumstances given the limited nature of the dishonesty and imposed a 12-month suspension.

In Durkin, the SRA withdrew a dishonesty allegation after accepting the solicitor’s explanation that he genuinely believed a client care letter had existed and was attempting to recreate it. He admitted lack of integrity and recklessness and received a 12-month suspension.

These cases confirm that strike-off for dishonesty will only be avoided in the most exceptional circumstances, typically where the dishonesty is momentary, isolated and causes no harm. Any attempt to cover up errors will be treated as seriously as, if not more seriously than, the underlying mistake.

• Using client account as a “banking facility” remains a perennial pitfall

All client account movements must relate to an underlying legal transaction. Using client account to move money for investment or convenience is prohibited.

In Fordyce, £1.1 million received from a politically exposed client was transferred through client account for investment purposes, with no underlying legal transaction. The Tribunal found this constituted use of client account as a banking facility.

WGS Solicitors admitted allowing client account to be used as a banking facility between 2018 and 2020, alongside multiple AML failures. The SDT imposed a £25,258 fine and £18,000 in costs.

• Vulnerable clients: capacity and conflict failures draw suspensions

Yusuf Siddiqui acted for both sides on the gift of an elderly client’s home to a neighbour. He was found to have overcharged, mishandled client money and failed to apply the appropriate capacity framework. He received a nine-month suspension.

The case reinforces the need for documented capacity assessments and proper conflict management in significant transactions involving vulnerable clients.

• How litigation is conducted matters as much as the outcome achieved

As officers of the court, solicitors must avoid attritional or abusive litigation tactics. In April 2025, the SDT imposed a 12-month suspension on Scott Halborg, who had brought multiple meritless applications as a claimant. He had been subject to limited and general Civil Restraint Orders and repeated judicial criticism. The SDT found his conduct amounted to a breach of integrity.

• Workplace culture matters

Conduct outside core legal work continues to attract sanctions. In an anonymised case, a partner who admitted making repeated overtly sexual comments to a junior colleague at a firm event was suspended for two years, alongside a treatment undertaking and costs exceeding £32,000. The SDT found high culpability and foreseeable harm.

In a controversial December 2025 decision, the SDT found that a drunken workplace kiss between managing partner Darren Roiser and a paralegal did not amount to professional misconduct. The Tribunal emphasised that the conduct was consensual and not instigated by Roiser, while criticising a workplace culture that encouraged excessive drinking.

Leadership and seniority elevate expectations. Firms must ensure workplace culture does not create environments where misconduct is foreseeable.

Conclusion

The 2025 SDT decisions send clear messages: AML compliance is non-negotiable; dishonesty will almost invariably end careers; vulnerable clients require heightened safeguards; and professional conduct extends beyond legal work to litigation tactics and workplace behaviour.

With prosecutions arising from the Post Office scandal, the collapse of Axiom Ince, and the Financial Conduct Authority set to take over AML supervision of law firms, 2026 is likely to be another significant year for the SDT. Watch this space.