Stefanie Anne O’Bryen

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

Stefanie Anne O'Bryen, sole owner/manager and MLRO/COLP/COFA of Watlington Solicitors, admitted eight allegations including failure to keep accurate accounting records, causing client account shortages (£6,079.73 and £3,487.10), failure to have a compliant Firm Wide Risk Assessment and AML policies, making a false and misleading declaration to the SRA about the FWRA (admitted careless/lacking integrity, not dishonest), inadequate CDD/EDD, and allowing a disbarred barrister ('Asad Sahi'/Yawar Ali Shah) and struck-off solicitor ('Edward Elkins'/Peter Hastings) to conduct legal services without due diligence or supervision. The Tribunal approved an agreed outcome of an 18-month suspension followed by indefinite practising restrictions, and ordered costs of £25,000. No express finding of dishonesty was made.

Duties found breached:

• Accounting records, reconciliation and reports
• AML and crime-prevention compliance
• No conflict between current clients
• No improper solicitation or touting
• No improper use of client money
• Proper basis for allegations
• Supervise staff and delegated work

Aggravating factors:

• Misconduct was not spontaneous and continued over a prolonged period
• Multiple failings identified across two forensic investigations
• Failure to undertake rudimentary identity/recruitment checks allowed a disbarred barrister (convicted fraudster) and a struck-off solicitor to work at the Firm using false identities
• Inadequate supervision led to poor service to clients and the demise of the Firm
• Repeated/long-standing client account shortages not promptly remedied

Mitigating factors:

• Full and frank admissions and co-operation with the SRA throughout
• Long (20+ years) and previously unblemished regulatory record
• Genuine remorse and apology
• Steps taken to mitigate effects on clients including remedial work and settlement of negligence claims; no client suffered loss as office account always covered shortfall
• Respondent was herself a victim of a sophisticated fraud by 'Asad Sahi' who was vouched for by other practising professionals
• Serious illness (breast cancer, radiotherapy, brain fog, fatigue) and diagnosed anxiety during relevant period; significant financial and personal hardship