Michael Ramsay

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

The Law Society alleged the Respondent breached Regulations 18, 19, 24, 28 and 33 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on Payer) Regulations 2017 in connection with shortcomings found during a November 2018 inspection of his incorporated practice, Ramsay & Co. Solicitors & Estate Agents Ltd. The Respondent raised a preliminary plea arguing he was not personally subject to the 2017 Regulations. The Tribunal rejected the Complainers' contention that the Respondent was a 'sole practitioner' (and thus an independent legal professional), holding that as a corporate body, the practice unit was a 'firm' and the use of 'or' in the definition was disjunctive - the Respondent could not be both. Following its reasoning in Law Society v Clancy, the Tribunal also found that the 2017 Regulations had not been incorporated into the 2011 Practice Rules until 3 May 2019, after the relevant transactions, so there was no personal duty under Rule B6.23/B6.2.3. The Tribunal answered both questions in the negative, upheld the preliminary plea, dismissed the Complaint, and awarded expenses to the Respondent. No finding of misconduct or dishonesty was made.