The club has been punished after an incident during the match against Northampton on May 6-9, after which the umpires submitted a report claiming the team had tampered with the ball.
They have been deducted eight championship points with a further nine suspended over the next year.
That points deduction would come into effect if Surrey were found guilty of another tampering offence before May 31, 2006.
The umpires report claimed that even after the Surrey captain had acknowledged the ball appeared to have been tampered with, further ball tampering occurred.
But no one has admitted responsibility.
A statement from Mr Elias QC said: "The report submitted to me (which I accept) indicated that despite their (the umpires) best efforts, no individual had accepted responsibility and they were unable to identify the culprit/s."
Surrey County Cricket Club accepted the accusations and launched an internal inquiry with the view to applying its own disciplinary procedures and has apologised for the action of the player or players involved.