Paul Christopher Flaherty; William John Gregory Osmond

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

The SDT approved agreed outcomes against two solicitors of Osmond Solicitors Ltd. First Respondent Osmond admitted knowingly allowing the firm's client account to be used as a banking facility for client Person A (approx £31.9m in, £28.3m out over 6 exemplified matters) and materially contributing to AML failures (no ongoing monitoring/EDD). He was found to lack integrity (Principle 2) but there was NO express finding of dishonesty. He was suspended 12 months with indefinite practising conditions and ordered to pay £50,000 costs. Second Respondent Flaherty, the firm's COLP/COFA, admitted allowing such payments by failing to investigate after accepting assurances from his co-partner; his misconduct was moderately serious, and he was fined £5,001 and ordered to pay £15,000 costs. Allegation 1.2.1 (CDD failure) against Osmond was withdrawn.

Duties found breached:

• Integrity
• Uphold public trust in the profession
• Non-discriminatory acceptance and cab-rank
• No conflict between current clients
• No improper use of client money
• Firm governance, systems and compliance
• Cooperate openly with regulators
• Not misrepresent regulated status

Aggravating factors:

• Misconduct deliberate/planned and repeated over more than three years
• Abuse of position of trust and authority
• Both experienced solicitors
• First Respondent's prior disciplinary history (1995 two-year suspension for Accounts Rules breach; 2015 £10,000 fine for being less than wholly frank on oath)
• Large sums (approx £30 million) passed through client account with no underlying legal transaction

Mitigating factors:

• No loss to any client or third party
• No profit from the transactions
• Cooperation with SRA investigation and admissions avoiding contested hearing
• Second Respondent's previous good character and clean regulatory history
• Second Respondent relied on assurances of trusted long-standing co-partner
• First Respondent stopped payments and returned funds once informed of Rule 14.5 breach