(unnamed respondent)

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

This was an application by John Davis (admitted 1978, sole principal of Davis-Law Associates) to remove conditions imposed on his practising certificate by a Tribunal order of 6 October 2021. The original 2021 proceedings concerned admitted breaches (improper provision of banking facilities through client account, conflicts of interest, AML failures, and failure to verify facts in professional correspondence), for which he received a £30,000 fine and £35,000 costs, with the conduct found to be reckless rather than dishonest. At the 2025 hearing he sought only to remove the first restriction (preventing him from acting as COLP, COFA, MLRO and MLCO). The Tribunal, applying Ebhogiaye, found he had not discharged the burden of proving rehabilitation or that the restriction was no longer necessary to protect the public, noting the absence of documentary/witness evidence. The application was refused and all 2021 conditions remained undisturbed. He was ordered to pay the Respondent's costs of £4,320.40 (including VAT).

Aggravating factors:

• Original breaches were serious and occurred over an extended period of time
• Mr Davis ought reasonably to have known the harm that would result

Mitigating factors:

• No other regulatory history; lengthy unblemished career
• Clearly an experienced and capable solicitor
• Cooperated favourably in original investigation
• No finding of dishonesty or financial gain in original proceedings