Paul Edmund Levy

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

Paul Edmund Levy, a solicitor admitted in 1999, acted in two unregulated secured loan transactions (Persons A and B) between September and December 2019 while a consultant at Singhania & Co Ltd. He failed to identify and respond to multiple indicators of potential fraud and/or money laundering and caused or materially contributed to the Firm's failure to comply with the 2017 MLRs (inadequate CDD/EDD). The transactions bore hallmarks of fraud, with imposter solicitors and payments requested to non-borrower parties. Allegations 1.1 and 1.2 were found proved on his admissions; the manifest incompetence allegation (1.3) was withdrawn with leave after late new evidence on identification. No dishonesty was alleged or found. The Tribunal imposed a £15,000 fine (Fine Band Level 3) and costs of £35,386.90, with no practising restrictions.

Duties found breached:

• Act in the client's best interests
• Non-discriminatory acceptance and cab-rank
• Good faith and courtesy to colleagues
• Not misrepresent regulated status

Aggravating factors:

• Misconduct occurred twice in rapid succession
• Previous appearance before the Tribunal in 2022 for Accounts Rules breaches, from which he had failed to learn
• Persisted in apportioning some blame to others despite accepting responsibility
• Potentially misled the regulator by providing relevant information only shortly before the substantive hearing
• Foreseeable risk of serious harm; failings led to identity fraud complaints affecting clients and victims

Mitigating factors:

• No allegation of dishonesty or recklessness; conduct was negligence/failure to identify warning signs
• Himself deceived and manipulated by sophisticated criminals
• Cooperated with the Applicant and made admissions, avoiding a contested hearing
• Demonstrated a degree of insight into his misconduct
• Undertook AML training and became MLRO for current firm (SRA had accepted on 7 July 2023 he was capable of holding MLRO position)
• Devastating personal impact and stress over many years, impact on mental health