Paul Christopher Flaherty; William John Gregory Osmond

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

The SDT approved Agreed Outcomes against two solicitors at Osmond Solicitors Ltd. Between 2014 and 2017 the firm received c.£31.9m and paid out c.£28.3m through its client account for client Person A's companies with no underlying legal transactions, using the client account as a banking facility contrary to Rule 14.5 SAR, plus AML monitoring/EDD failures. First Respondent William Osmond admitted breaches including a lack of integrity (Principle 2) - but NO dishonesty was alleged or found; he was suspended 12 months with indefinite practising restrictions and ordered to pay £50,000 costs. Second Respondent Paul Flaherty (COLP/COFA) allowed the payments by relying on assurances of his co-partner without further enquiry; his misconduct was moderately serious and he was fined £5,001.00 and ordered to pay £15,000 costs. No dishonesty was found against either respondent.

Duties found breached:

• Cooperate openly with regulators
• Firm governance, systems and compliance
• Good faith and courtesy to colleagues
• Integrity
• No conflict between current clients
• No improper use of client money
• Non-discriminatory acceptance and cab-rank
• Not misrepresent regulated status
• Uphold public trust in the profession

Aggravating factors:

• Misconduct continued over a period of more than three years
• Large number and high value of transactions (approx £30 million through client account)
• First Respondent's misconduct was deliberate, calculated and repeated
• Abuse of position of trust/authority as owner/manager
• First Respondent was an experienced solicitor (admitted 1979)
• First Respondent's prior disciplinary history: 1995 (two-year suspension for Accounts Rules breach) and 2015 (£10,000 fine for being 'less than wholly frank' on oath)
• Second Respondent acted in breach of his obligations as COFA and director over nearly three years

Mitigating factors:

• No loss caused to any client or third party
• No evidence Respondents profited from the misconduct
• First Respondent stopped payments and returned funds once informed of Rule 14.5 by accountants
• Second Respondent relied on assurances of his trusted co-partner of over 10 years
• Second Respondent had no previous regulatory history
• Second Respondent took his COLP/COFA roles seriously in other respects; conduct limited to four matter files