Peter Kenneth Felton Gerber

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

Sole practitioner and COLP/COFA/MLRO of Feltons Law faced allegations relating to AML compliance failures, false statements to insurers and the SRA about AML training and a firm-wide risk assessment, use of the client account as a banking facility (£4.4m), and failure to return residual client funds promptly. He admitted the factual/technical breaches but denied dishonesty, lack of integrity and recklessness. The Tribunal expressly found he was NOT dishonest, accepting his beliefs were genuinely (though unreasonably) held, but found lack of integrity and recklessness, with all breaches proved (dishonesty not proved on Allegations 1.1 and 1.3). Sanction: £45,000 fine plus indefinite practising restrictions (suspended until 4 April 2025), and costs of £60,000.

Duties found breached:

• AML and crime-prevention compliance
• Firm governance, systems and compliance
• Good faith and courtesy to colleagues
• Integrity
• No conflict between current clients
• No improper use of client money
• Prompt accounting and return of money
• Proper basis for allegations
• Uphold public trust in the profession

Aggravating factors:

• Misconduct embedded and persisted over several years without remedy
• Failed to take remedial action despite shortcomings being pointed out by the FIO and others (took at least two further years)
• Conduct found to be reckless
• Experienced solicitor who should have known better
• Placed clients at risk
• Limited insight into potential harm to clients

Mitigating factors:

• No dishonesty found
• No improper gain and no loss to any party
• No complaints or claims against him
• 33 years of unblemished practice; first appearance before the Tribunal
• Strong character references
• Full cooperation with the SRA
• Early admissions to factual matters and Accounts Rule breaches
• Genuine remorse; struggling as a sole practitioner
• Eventually became fully compliant

⚠ figures not found verbatim in the source were dropped: ["review_dishonesty_finding_cue_present"]