Ian James Douglas & Second Respondent

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

Both respondents at Cook & Partners caused/permitted large client account shortages (up to c.£1m), unallocated client-to-office transfers of £302,193.31, failed reconciliations and failed to report breaches. First Respondent (Douglas, sole equity partner and COFA) admitted all allegations including dishonesty; the Tribunal found no exceptional circumstances and struck him off the Roll. Second Respondent (COLP, former founder) admitted breaches including lack of integrity but not dishonesty (dishonesty allegation withdrawn); he was suspended for 5 years. Each ordered to pay 50% of summarily assessed costs (£10,100 each; £20,200 total). No fines imposed.

Duties found breached:

• No conflict between current clients
• No improper use of client money
• Accounting records, reconciliation and reports
• Diligence and timeliness
• Firm governance, systems and compliance
• Report serious misconduct of others
• Not misrepresent regulated status

Aggravating factors:

• Dishonesty (First Respondent) - deliberate, calculated and repeated over a period of time
• Took advantage of vulnerable/bereaved clients, misusing Estate monies
• Concealed wrongdoing from the SRA and from the Second Respondent
• Previous appearance before the Tribunal in September 2014 for similar Accounts Rules breaches (both Respondents fined £7,500 plus £15,000 costs)
• Considerable harm - claims on SRA Compensation Fund of £902,668.02 across 40 payments
• Second Respondent's failure to act as COLP was repeated and facilitated the misconduct despite being on notice

Mitigating factors:

• First Respondent made early admissions, including admitting dishonesty, and was frank in interview
• First Respondent suffering from depression and alcohol difficulties; took courage to attend hearing
• Second Respondent had no direct control of accounts and was not responsible for the transfers; deceived by First Respondent
• Second Respondent made early admissions and had no personal gain or benefit
• Second Respondent's culpability was significantly less than the First Respondent's