CD&R Galaxy UK Opco Limited fined £33,438
CD&R Galaxy UK Opco Limited has agreed to a financial penalty and investigation costs following regulatory breaches identified by the Solicitors Regulation Authority.
In a recent enforcement decision, the Solicitors Regulation Authority (SRA) has levied a fine of £33,438 against CD&R Galaxy UK Opco Limited for failing to comply with crucial anti-money laundering regulations. The firm, which operates as a Licensed Body under the supervision of the SRA, admitted to systematic deficiencies in its compliance procedures concerning the Money Laundering, Terrorist Financing (Information on the Payer) Regulations 2017.
The SRA's investigation revealed that from April 2022 to October 2024, CD&R Galaxy lacked a written Firm-wide Risk Assessment (FWRA), a critical requirement since June 2017. Despite the firm stating it was in the process of drafting this document, it failed to present a compliant FWRA during the pre-inspection questionnaire period. Only after further correspondence did the firm submit an FWRA, including earlier drafts from 2024. Although the firm has since rectified its FWRA deficiencies, the lack of compliance during its operational timeline highlighted significant regulatory breaches.
Additionally, the investigation uncovered failures in conducting Client and Matter Risk Assessments (CMRAs) across its dealings, violating specific regulations of the Money Laundering Regulations. These shortfalls posed risks associated with dubious transactions potentially leading to money laundering or terrorist financing. The firm's previous ownership had also contributed to an inadequate level of customer due diligence, leaving several files non-compliant.
The SRA deemed a financial penalty necessary as it reflects a commitment to uphold public trust and ensure compliance within the legal profession. The decision to impose such a fine was supported by the firm’s cooperation throughout the investigation and its proactive measures to amend its compliance procedures. The SRA recognised that while the conduct could have had severe repercussions, no actual harm had occurred due to these breaches.
In total, the penalties also include reimbursement of £600 for investigation-related costs to the SRA. The firm must pay these costs within 28 days of a formal statement issued by the SRA. The financial penalty reflects the seriousness of the firm’s past non-compliance yet offers a pathway for future compliance and improvement within its practices.
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