Dennis Ko

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

Dennis Ko, a partner at Kennedys Law LLP overseeing the Grosvenor Hotel Bristol development, admitted failing to conduct adequate client due diligence and ongoing monitoring, causing breaches of money laundering regulations, and acting in/authorising payments (including £925,000 to Mr Varma personally) in transactions bearing the hallmarks of fraud. The scheme was later found to involve substantial fraud by Mr Varma. The SRA withdrew allegations of lack of integrity, recklessness and Principle 2 breaches; no dishonesty was alleged or found. The Tribunal approved an Agreed Outcome imposing a Level 4 fine of £27,500 and costs of £25,000, finding suspension or strike-off unnecessary.

Duties found breached:

• Proper basis for allegations
• No conflict between current clients
• No improper use of client money
• Competence
• Report serious misconduct of others
• Not misrepresent regulated status

Aggravating factors:

• Misconduct spread over a number of months
• Respondent was a partner with fourteen years on the Roll at the material time
• Very large sums of client money paid out (over £5.2m through client account while at the Firm) with substantial fraud ultimately occurring

Mitigating factors:

• No dishonesty, lack of integrity or recklessness found (allegations withdrawn)
• Not motivated by financial gain
• Full cooperation with the SRA investigation and significant admissions
• Assisted liquidators' litigation and described by the judge as an honest and straightforward witness
• Deceived by Mr Varma; other partners also considered it appropriate to continue acting
• Undertook remedial AML training and adopted more cautious practices
• Delay in the SRA investigation causing stress