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SRA Disqualifies PM Law’s Jonathon Bostock Over £39.5m Client Money Fraud

Susan Stein 3 min read

The Solicitors Regulation Authority has barred a non-solicitor finance chief from working at any law firm in England and Wales, its toughest available sanction for someone outside the profession, after finding he falsified accounts and misled the regulator during the collapse of PM Law.

Jonathon Howard Bostock, who served as head of finance and administration across the PM Law group from January 2013 until February 2026, was disqualified under section 99 of the Legal Services Act 2007.

The provision allows the SRA to remove non-solicitors from roles at alternative business structures, and it was used here because disciplinary routes reserved for solicitors did not apply to Bostock.

He managed finance functions across twelve firms within the group, including six ABSs where he served as head of finance and administration and six non-ABS firms where he held the role of compliance officer for finance and administration, reporting throughout to Donald Mackay, the solicitor who owned and chaired the business.

The SRA’s findings describe a deliberate pattern rather than an isolated lapse. Bostock caused or allowed withdrawals that produced a shortfall in client accounts, then fabricated bank balances across several accounts to misrepresent the firm’s financial position to a third party.

He also supplied the regulator with information he knew or should have known was false, and failed to flag the deteriorating position even as shortages worsened. PM Law itself only alerted the SRA to concerns about client money on 2 February 2026; the regulator intervened into all but one of the group’s firms within two days.

The case sits alongside Axiom Ince and SSB Law as the third major intervention in recent years to draw sustained scrutiny of the SRA’s supervisory model, and the Legal Services Board has already pressed the regulator to explain how a shortfall approaching £40m went undetected for so long.

That pressure has pushed the SRA toward faster, more visible enforcement in complex ABS structures, and the Bostock disqualification is the clearest evidence yet of that shift — a sanction delivered within months of intervention rather than the years such investigations have historically taken.

The Law Society has previously said the case reinforces why the regulator needs to focus on core supervisory functions rather than expanding its remit.

Compliance officers and finance leads working inside ABS and multi-entity firm structures now face an unambiguous precedent: personal exposure under section 99 does not depend on holding a practising certificate, and regulators are moving on non-solicitor managers with the same speed previously reserved for solicitor principals.

Bostock was also ordered to pay costs of £1,350, a modest figure against the scale of the underlying losses but a marker that the SRA intends to pursue individual accountability in parallel with its wider investigation into PM Law’s solicitor managers, which remains ongoing.

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