Caroline Jones & Hillyer McKeown LLP

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

Caroline Jones (solicitor) and her firm Hillyer McKeown LLP admitted misconduct relating to involvement in SDLT avoidance schemes between 2010 and 2014. The firm undertook 113 SDLT scheme conveyancing transactions (85 involving lender clients), failing to advise purchaser clients adequately on scheme risks, failing to inform lender clients, improperly transferring funds without lender consent, acting in conflict of interest, improperly seeking to limit liability, and breaching Accounts Rules. The Tribunal found the misconduct moderately serious. It expressly noted there was no dishonesty or lack of integrity. By agreed outcome, the First Respondent was fined £7,000 (reduced for means) and the Second Respondent £10,000, with each paying £15,000 in costs.

Duties found breached:

• Disclose referrals, commissions and benefits
• Firm governance, systems and compliance
• No abuse of process or coercive powers
• No conflict between current clients
• No improper solicitation or touting
• No improper use of client money

Aggravating factors:

• Absence of self-reporting by either Respondent
• Conduct continued over a period of time (approximately 4 years)
• Conduct was not spontaneous
• Conduct generated fees of around £90,000

Mitigating factors:

• No relevant regulatory history; good character
• Full and open admissions to each allegation
• Genuine insight and full cooperation with the SRA
• Practice ceased before SRA investigation commenced
• No dishonesty, lack of integrity or ulterior motivation
• No client complaint from purchaser clients and no known loss to lender clients
• First Respondent's personal financial means taken into account
• Time-bar clauses inadvertently used from previous employer precedent and not relied upon