Decision record
Pascale Edith Marie-Anne Wood-Atkins
Allegation / charges
Breaches, Failures
Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision
The Respondent, a sole practitioner solicitor, acted as 'paymaster' for Provartis AG in a fraudulent investment scheme. She received investor funds into her client account, having represented that all funds would be safely held and transferred to Deutsche Bank/Commerzbank accounts. In fact she knew only a portion would be transferred and paid substantial sums to third parties and to her own office account (paying off the firm's arrears), and falsely told investors their money was still in her client account. The Tribunal found express dishonesty on allegations 1.1.2, 1.1.3, 1.1.4, 1.2, 1.3 and 1.9 (applying the Twinsectra combined test), while finding lack of integrity/recklessness (not dishonesty) on 1.1.1 and 1.1.5. She also breached the Accounts Rules by providing banking facilities, failing to reconcile non-sterling accounts, and failing to return client money promptly. One allegation (failure to notify serious financial difficulty) was not proved and one (1.6) was withdrawn. Despite strong character evidence and being duped by fraudsters, the Tribunal found no exceptional circumstances and struck her off, ordering costs of £70,000.
Duties found breached:
- Integrity
- No taking unfair advantage
- Uphold public trust in the profession
- No conflict between current clients
- Segregate client money
- Prompt accounting and return of money
- Accounting records, reconciliation and reports
Aggravating factors:
- Dishonesty found in relation to allegations 1.1, 1.2, 1.3 and 1.9
- Facilitated a fraud perpetrated on investors who lost money
- False representations sent to several investors over a period of at least a month, giving opportunity to reflect
- Lack of insight into her own misconduct, appearing to view herself as the victim
- Ignored the SRA warning card on fraudulent financial arrangements of which she was aware
- Numerous warning signs present in the scheme (unrealistic 40% monthly returns, poor directorship records, forged-looking documents)
Mitigating factors:
- No previous disciplinary findings
- Many impressive written and personal character references attesting to honesty
- No underlying predisposition to dishonesty
- Duped, groomed and exploited by sophisticated fraudsters
- Not motivated by pursuit of money and not herself part of the fraud
- Dishonesty confined to one client/group of linked clients over a comparatively short period
Duties engaged
- Honesty
- Integrity
- Professional independence
- No taking unfair advantage
- Not mislead third parties or opponents
- No bribery or improper gifts
- Personal probity and fitness to practise
- Uphold public trust in the profession
- No unlawful discrimination or harassment
- Advise objectively, not a mere conduit
- No conflict between current clients
- Segregate client money
- Prompt accounting and return of money
- Accounting records, reconciliation and reports
- Self-report to the regulator