Douglas Kihiko Wamburu

Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision

Duties found breached:

• Accounting records, reconciliation and reports
• Cooperate openly with regulators
• Not misrepresent regulated status
• Orderly wind-down and contingency cover
• Proper basis for allegations

Aggravating factors:

• Manifest incompetence alleged as an aggravating factor across all allegations

Mitigating factors:

• Admitted all allegations
• Matter resolved by agreed outcome
• Reduced costs figure reflecting respondent's means