Rory Peter Heddle Fordyce

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

Rory Peter Heddle Fordyce, a manager, director, COLP, MLCO and MLRO of Taylor Fordyce Limited, faced five allegations. The Tribunal found allegations 1.1, 1.2 and 1.3 proved. He failed to take adequate measures to establish the source of wealth and funds of Anar Mahmudov, a Politically Exposed Person (son of Azerbaijan's national security minister), in relation to receipts of £1,100,000 (Jan 2014) and £1,946,602.88 (Apr 2015); his checks were found to be rudimentary, piecemeal and naïve, and he prioritised the transaction over his regulatory obligations despite holding contradictory source-of-funds information. He also used the firm's client account as a banking facility for the £1.1m and for his own personal payments. Allegations 1.4 (borrowing from Mahmudov - no own-interest conflict found) and 1.5 (loan to a person who was not a client at the time) were not proved/dismissed. No express finding of dishonesty was made. The Tribunal imposed a £32,500 fine, £50,000 costs and five-year practice restrictions.

Duties found breached:

• No baseless or threatened misconduct report
• No improper use of client money
• Non-discriminatory acceptance and cab-rank
• Not misrepresent regulated status
• Proper basis for allegations