Paul Edmund Levy

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

While a solicitor/consultant at Singhania & Co Ltd, Levy acted in two unregulated secured loan transactions (involving Person A and Person B) between Sept-Dec 2019 and failed to identify or respond to multiple indicators of potential fraud and/or money laundering. The Tribunal found allegations 1.1 and 1.2 proved on his admissions: he failed to act in clients' best interests, undermined public confidence, failed to maintain competency, and caused/materially contributed to the Firm's failure to undertake adequate CDD/EDD under the 2017 MLRs. Allegation 1.3 (manifest incompetence) was withdrawn with leave after new evidence on identification was submitted. The Tribunal imposed a Level 3 fine of £15,000 plus costs of £35,386.90. No dishonesty or recklessness was alleged or found.

Duties found breached:

• Act in the client's best interests
• Non-discriminatory acceptance and cab-rank
• No conflict between current clients
• AML and crime-prevention compliance
• Good faith and courtesy to colleagues