Caroline Jones & Hillyer McKeown LLP

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

Solicitor Caroline Jones and her firm Hillyer McKeown LLP were found to have facilitated 113 SDLT avoidance scheme transactions between 2010 and 2014 without providing adequate advice to purchaser clients, failing to inform lender clients, improperly transferring funds to third parties, acting in conflict of interest, improperly limiting liability, and breaching accounts rules. The Tribunal approved an Agreed Outcome on the papers, finding the misconduct moderately serious. It expressly found no dishonesty, lack of integrity or ulterior motivation. Jones was fined £7,000 (reduced for means) and the firm £10,000, each paying £15,000 costs.

Duties found breached:

• Act in the client's best interests
• Disclose referrals, commissions and benefits
• No conflict between current clients
• No improper use of client money
• Report serious misconduct of others
• No improper solicitation or touting

Aggravating factors:

• Absence of self-reporting by either Respondent
• Conduct continued over a period of time (approximately 4 years)
• Conduct was not spontaneous
• Firm was a Panel member for the scheme provider and held expertise in the area

Mitigating factors:

• No relevant regulatory history; both of good character
• Full and open admissions at an early stage in relation to each allegation
• Full co-operation with the SRA
• Genuine insight demonstrated
• Practice ceased before the SRA investigation commenced
• No dishonesty, lack of integrity or ulterior motivation
• No client complaints from purchasers and no known loss to lender clients
• First Respondent's personal financial means taken into account