In December 2018, former solicitor Kevin Robert Manning (62) was sentenced to three and a half years in prison, having pleaded guilty to the offences earlier in the year.

The indictments were as follows:-
1. First Indictment
a. 20 counts of: Fraudulent conversion (Counts 7, 8,10,11, 12, 14,15, 16, 17, 18, 19, 21, 22,
b. 23, 24, 25, 26, 28, 31, 32).
c. 1 count of: Fraudulent conversion by a trustee (Count 20),
2. Second Indictment
a. 1 count of: Failing to comply with the requirements of Article 19 [RECORD KEEPING] of the Money Laundering
b. (Jersey)l Order 2008 [MLJO]. Contrary to Article 37(4) of the Proceeds of Crime (Jersey) Law 1999. (Count 5).
The Money laundering charges were in regard to the 2008 Money Laundering (Jersey) Order – he failed to
1. accurately label transactions passing through his client account.
2. Failing to record balances of client accounts and failing to record transactions accurately, or at all.
3. Comply with money-laundering laws by not adopting or applying any internal policies or procedures designed to prevent and detect money laundering.
4. To maintain, keep and accurately account for client funds to the extent that no reconstruction of individual transactions could take place.
His offending came to light after the Law Society began investigating his eponymous practice in 2014.
‘If matters come to our attention, or are raised in the course of our work, we will certainly investigate,’ chief executive Neville Benbow said following Manning’s sentencing by the Superior Number.

‘The issues with Mr Manning’s practice and, significantly, a potential shortfall in client funds which had been entrusted to Mr Manning, were identified by the Law Society of Jersey and immediately referred to the Solicitor General, following which Mr Manning was suspended from practice, and a receiver for his business assets was appointed.’

https://www.jerseylawsociety.je/news-room/news/jersey-solicitor-jailed-client-account-fraud/

Also, see attached

NOTES – EXTRACT FROM MLJP
19 Records to be kept
(1) A relevant person must keep the records specified in paragraphs (2) and (2A).[123]
(2) This paragraph refers to –
(a) a record comprising –
(i) a copy of the evidence of identity obtained pursuant to the application of customer due diligence measures or information that enables a copy of such evidence to be obtained, and
(ii) all the supporting documents, data or information that have been obtained in respect of a business relationship or one-off transaction following the application of customer due diligence measures;
(b) a record containing details relating to each transaction carried out by the relevant person in the course of any business relationship or one-off transaction.[124]
(2A) This paragraph refers to the records, if any, that –
(a) the relevant person was required to keep immediately before 4th February 2008 under record keeping procedures maintained under Article 8 of the Money Laundering (Jersey) Order 1999[125]; and
(b) the relevant person held immediately before 19th February 2008.[126]
(3) The record to which paragraph (2)(b) refers must in any event include sufficient information to enable the reconstruction of individual transactions.
(4) The relevant person must keep the records to which paragraphs (2) and (2A) refer in such a manner that those records can be made available on a timely basis to the Commission, the Financial Intelligence Unit, a police officer or customs officer for the purposes of complying with a requirement under any enactment.[127]
(5) Where an obliged person who is a relevant person has given an assurance under Article 16 (or under a provision that applies outside Jersey that is equivalent to Article 16) to another relevant person, the obliged person must make available to that other relevant person, at the other relevant person’s request, evidence of identification that the obliged person is required to keep under this Article, such evidence being the evidence that is referred to in Article 16(3)(d) (or in a provision that applies outside Jersey that is equivalent to Article 16(3)(d)).[128]
(6) Where a relevant person has given an assurance to another person that is required under Article 17 (or under a provision that applies outside Jersey that is equivalent to Article 16(3)(d) or Article17), the relevant person may make available to that other person, at that other person’s request, the information or the evidence of identification that the relevant person is required to keep under this Article, such evidence being the information and evidence that is referred to in Article 17(9)(c) (or in a provision that applies outside Jersey that is equivalent to Article 16(3)(d) or 17(9)(c)).[129]
(7) A relevant person may make available to a another person, being a person who is carrying on an equivalent business, at that other person’s request, a copy of the evidence, documents, data and information referred to in Article 15(4B)(f).[130]

https://archive.comsuregroup.com/wp-content/uploads/2019/01/MANNING-SENTENCING.pdf