Stephen McGuire

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

Stephen McGuire, Designated Cashroom Manager and MLRO at Hennessey Bowie & Co, was found guilty of professional misconduct in cumulo following inspections in 2013, 2015 and 2016 that revealed persistent and unrectified breaches of the Accounts Rules and Money Laundering Regulations. Failures included incorrect client identification on ledgers, payments to non-clients and to clients under new names without identification/due diligence/written authority, failure to implement and monitor AML risk assessments and record keeping, failure to train staff, and knowingly permitting his partner (Alistair Bowie, since struck off) to practise in breach of obligations. The Complainers did not rely on breach of Rule B1.2 (honesty and integrity); no dishonesty finding was made. The conduct was assessed at the lower to middle end of the scale. The Tribunal censured the Respondent, fined him £1,000, and found him liable for the expenses of the Complainers and the Tribunal (taxed). Publicity was directed, naming the Respondent and his former partner.

Duties found breached:

• Act only on proper, lawful instructions
• AML and crime-prevention compliance
• No conflict between current clients
• Not mislead third parties or opponents
• Not misrepresent regulated status

Aggravating factors:

• Ongoing course of conduct over approximately three and a half years
• Repeated failures identified in 2013 and 2015 not rectified by 2016
• Conduct likely to damage the legal profession
• Risk of money being paid in breach of the Proceeds of Crime Act 2002