This digest relates to cases published by the respective regulators during week ending 11 September 2026 which have sufficient detail to allow us to comment.
One Solicitors Disciplinary Tribunal (SDT) judgment (which also concerns the Bar) was published this week and one finding of a BSB Disciplinary Tribunal (BSBDT), together with a determination by consent from the BSB and 14 regulatory decisions from the SRA. The two tribunal decisions share a subject: what a practitioner owes a body that is not the client.
The SDT judgment in SRA v Zeeshan Saqib Mian (case number 12824) concerns a solicitor who sought to be called to the Bar while under SRA investigation and who was called after conditions had been imposed on his SRA practising certificate. He told neither the BSB nor his Inn about any of it. He is not the practitioner of the same surname covered in the digest for week ending 17 July 2026, and the facts are unconnected, but the two cases do meet on a point I return to below.
He signed the Inn’s Admission Declaration and Call Declaration on 4 May 2016, knowing by then that an investigation was ongoing against him by the SRA. Both declarations required disclosure of anything which might reasonably be thought to call into question his fitness to become a practising barrister, and both directed disclosure in case of doubt. Conditions were imposed on him by the SRA on 2 September 2016 and upheld by an SRA Adjudication Panel on 2 November 2016. He was called to the Bar on 24 November 2016, having notified neither the Inn nor the BSB.
The allegation about the BSB’s own admission form was not proved: the SDT found that its wording created no sufficiently clear obligation and carried no express warning to disclose if in doubt. The Inn’s declarations did, and the failure to disclose at that stage was proved as a breach of Principles 2, 6 and 7 of the SRA Principles 2011, with recklessness rather than dishonesty. The failure to notify the conditions once imposed and upheld was proved including dishonesty, the SDT rejecting his explanation that he believed them irrelevant because they concerned only the management of a solicitors’ practice. After call he was subject to the BSB Handbook, and the judgment records that rule C65.3 required prompt reporting where a barrister is, to their knowledge, the subject of disciplinary or other regulatory or enforcement action by another Approved Regulator. His failure to report was also found dishonest.
Culpability was found to be high: deliberate, repeated across years, and motivated by a desire to avoid the risk that disclosure would affect his admission, call or standing at the Bar. The SDT found no significant mitigation, no voluntary notification, no meaningful insight and no evidence of remediation. He was struck off the Roll, with costs of £40,000.
The BSB register records a disbarment against this practitioner following a Disciplinary Tribunal in June 2022, effective June 2023, based on substantially the same facts.
Competence mapping
Competence A1c requires solicitors to identify the relevant SRA principles and rules of professional conduct and to follow them, competence A1a requires ethical issues to be recognised and effective judgment exercised in addressing them, and competence A1b requires an understanding and application of the ethical concepts which govern a lawyer’s role and behaviour. The question was straightforward: whether a condition imposed by one regulator, and upheld on appeal, is the kind of thing another regulator would want to know before admitting somebody. Competence A5a requires information to be assessed so as to identify key issues and risks and competence A5e requires reasoned decisions to be supported by relevant evidence. His account was that he asked himself whether, as a barrister, he would perform the functions the conditions restricted. The declaration was not directed at that question but at matters which might reasonably be thought to call into question fitness, which is a judgment for the body receiving it, not for an individual to selectively withhold.
Competence A1d requires solicitors to resist pressure to condone, ignore or commit unethical behaviour, and the Tribunal’s finding on motive puts that pressure in his own interest rather than anybody else’s.
This is the second time this summer that the digest has come to the boundary between the two regulators. In July we covered a practitioner qualified as both solicitor and barrister whose conduct was tried twice on the same facts: the Solicitors Disciplinary Tribunal heard it in February 2025, a Bar Disciplinary Tribunal made its findings in July 2026. Here the order is reversed and the interval is longer. BTAS recorded above determined the matter in June 2022; the SDT came to the same conduct four years later. Conditions were imposed by the SRA in September 2016, and the judgment records that the BSB did not notify him of its decision to investigate until 20 December 2018. Whatever passes between regulators, the only person holding the whole regulatory history at the moment a declaration is signed is the practitioner. That is why disclosing it is a personal obligation.
Three tax years, six years of liabilities
The BSB register records a finding of a three person BSBDT against Nicholas Gerard Hugh Barnes on 9 September 2026, for professional misconduct contrary to Core Duty 3, Core Duty 5 and Core Duty 10 of the Code of Conduct and rule C87.1 of the Conduct Rules. Five particulars fall into two groups. Three concern the late filing of self assessment tax returns for one or more of the tax years ended 5 April 2019, 2020 and 2021, charged as acting without integrity, as a failure to manage the practice competently and administer it properly, and as behaviour likely to diminish public trust and confidence. Two concern a failure to pay promptly, or at all, the liabilities outstanding on his self assessment statement for the six years ended 5 April 2024, which the register puts at approximately £279,934.02, charged as a failure of practice management and as behaviour likely to diminish public trust and confidence. The integrity particular attaches to the returns and not to the unpaid liabilities.
He was fined £18,000, payable in equal instalments over 12 months, with costs of £4,650. The finding is open to appeal. Neither the register nor the BTAS has published reasons at this stage.
Competence mapping
Core Duty 10 obliges a barrister to take reasonable steps to manage their practice competently and in such a way as to achieve compliance with their legal and regulatory obligations, and rule C87.1 obliges them to take reasonable steps to ensure the practice is efficiently and properly administered having regard to its nature. Competence 4.2 of the Professional Statement for Barristers requires sufficient understanding of organisational and management skills to maintain an effective and efficient practice, and sub point 4.2(a) requires competence in all aspects of the work, including organisation, management of practice and risk. The Professional Statement says that competent organisation includes keeping accurate financial records, prioritising, diarising and observing deadlines; competent risk management includes measuring the probability and severity of risks to the practice, then deciding what to do about them and acting.
Sub point 4.1.1(b) requires a self employed barrister to demonstrate a thorough understanding of the commercial, organisational and financial context in which they work and their place in it. Competence 2.5 requires a reflective approach which enables errors to be corrected and mistakes admitted, with sub point 2.5(c) requiring errors and omissions to be identified and appropriate action taken and sub point 2.5(d) requiring guidance and support to be asked for and used. The charges distinguish the two groups: the late returns were charged as a failure of integrity as well as of practice management, the outstanding liabilities were not. The Bar’s competence framework places the administration of a self employed practice inside the professional skill set rather than beside it.
A determination by consent
The BSB also published a determination by consent in the case of Alexander Paul Riddiford, case reference 2025/3045/DC, a disposal agreed by consent and determined by a panel rather than by a Disciplinary Tribunal. The single charge was professional misconduct contrary to Core Duty 5. On 27 September 2025 the barrister drove with 65 micrograms of alcohol in 100 millilitres of breath against a prescribed limit of 35, colliding with a roundabout. He pleaded guilty at Croydon Magistrates Court and was disqualified from driving for 18 months, reducible by 18 weeks on completion of a drink drive awareness course. The panel imposed a fine of £2,500 and the finding is open to appeal.
Competence mapping
Sub point 2.1(e) of the Professional Statement requires barristers to take responsibility for their actions and decisions, and sub point 2.5(c) requires them to identify their errors of judgement, omissions and mistakes and take appropriate action. The conduct was outside practice. The response to it was not. He reported himself on the day, admitted the charge from the outset, cooperated with both investigations and completed a rehabilitation course before the panel sat. The mitigating factors the panel listed read as a transcription of what those points in the Professional Statement for Barristers require.
SRA regulatory disposals
The SRA published 14 decisions during the week, after a week in which it published none. Four concern anti money laundering obligations, and each began with the regulator’s own proactive supervision rather than with a complaint. Michael Taylor Solicitors & Co agreed a penalty stated as £9,511 although the agreement’s own calculations arrive at £8,454, Moss Solicitors LLP one of £18,738 and Steinfeld Law LLP one of £2,160, in each case for failing to record client and matter risk assessments; Michael Taylor Solicitors & Co had also been without a compliant firm wide risk assessment and adequate due diligence records, and Moss Solicitors LLP without compliant policies, controls and procedures. Knipe Woodhouse-Smith was fined £8,211 with costs of £1,350, its conduct placed mid-band in band C at 2.4% of annual domestic turnover, because it had no documented firm wide risk assessment between June 2017 and March 2023 and did not produce fully compliant documentation until April 2026 having entered a compliance plan in October 2024 and then failed to cooperate with the SRA for 18 months.
The common feature is not that these firms had done no work on money laundering risk. It is that they could not show what they had done. Regulation 28(16) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 requires that the relevant person must be able to demonstrate to its supervisory authority that the extent of the measures taken is appropriate in view of the risks. Against that obligation, an assessment carried out and not recorded is an assessment not carried out.
Bryn Roberts, a sole practitioner at Evans Roberts, was fined £20,148.75 with costs of £1,350. Two forensic investigations identified a client account shortage of £30,848.73 which had lasted almost three years, no client account reconciliations and a late accountant’s report. He was found to have authorised an improper transfer from client account, failed to keep proper books of account, failed to comply with an undertaking, to act in clients’ best interests and in a timely manner, to respond to complaints and to cooperate with the Legal Ombudsman and the SRA. No mitigating factors were recorded.
Three orders disqualified people who are not solicitors: Shahbaz Jaffar of Nayyars Solicitors Limited, for false claims to insurance providers for services never provided; Lauren Dunn of Co-operative Legal Services, for misleading a client about when a probate application had been submitted, in each case with a finding of dishonesty; and Jennifer Dent, formerly of IME Law Limited, whose decision gives no facts, so I express no view. The remaining disposals are an intervention into Traymans LLP, interim conditions on the certificates of Lindsay Goodson and conditions on Queen Appahoh’s certificate, a rebuke of Gurbinder Singh Sangha following a conviction for failing to provide a specimen of breath, and a referral of Aarti Kotecha to the Tribunal, where the allegations are unproved and I express no view.
The competences engaged by this week’s SRA disposals are competence D2, which requires records that are accurate, complete and clear, competence D3c, which requires the rules of professional conduct to be applied to accounting and financial matters, and competences C2i and C2j, which require clients to be informed in a timely way of progress and their complaints responded to appropriately.
Closing thoughts
Two threads run through the week. We return to the question of evidence for the second week in a row: the first is the distance between doing something and being able to show it. Every anti money laundering decision turns on records which were not kept rather than on risk which was not considered, and the same idea sits underneath the sole practice fine, where the absence of reconciliations meant nobody could tell what the position was. The second is what a practitioner owes somebody who is not the client. Both tribunal decisions are about that, one concerning a second regulator and the other the tax authority. Neither involves a client who lost money and neither turns on the quality of any legal work. What each was found to have put at risk was public trust in the profession: Principle 6 of the SRA Principles 2011 in the solicitor’s case and Core Duty 5 in the barrister’s. One produced a fine and the other a strike off.
Worth restating, because it recurs: competence A3b of the Statement of Solicitor Competence requires solicitors to recognise when they have made mistakes or are experiencing difficulties and to take appropriate action, and competence A3c requires guidance and support to be sought where needed, with sub points 2.5(a), 2.5(c) and 2.5(d) of the Professional Statement for Barristers putting the same duty on barristers. In more than one decision this week a problem which was manageable when it arose was left in place, and it was the leaving rather than the original failure which shaped the sanction.
One decision records unspecified personal circumstances in mitigation, and sub point 2.5(e) requires barristers to manage personal difficulties which might otherwise affect their work. Where practitioners are carrying that kind of load, or dealing with the stress of an investigation or of tribunal proceedings, LawCare‘s free and confidential helpline, 0800 279 6888, remains available to anyone in the legal sector.
A lesson this week’s decisions teach: an obligation nobody is chasing you for is still an obligation, and this week the SDT and a BSBDT each sanctioned a practitioner who had left one unmet for years.
Beyond Competence Limited, for information and educational purposes only. This digest does not constitute legal advice.
