George Fahim Sa’id

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

George Fahim Sa'id, a sole practitioner, faced four allegations of failing to carry out adequate enhanced customer due diligence (Regulation 33) and failing to have appropriate risk management systems to establish source of wealth/funds (Regulation 35) under the MLRs 2017, in relation to the purchase of 'The London Hotel' and 'The London House', involving clients connected to a Country X government Minister (a PEP). It was alleged he breached Principles 6, 7 and 8 of the SRA Principles 2010 and failed to achieve Outcome 7.5. Sa'id accepted he made errors—chiefly that his electronic search system (Veriphy) failed to identify a PEP and that he should have classified the transactions as high risk—but denied these amounted to professional misconduct. The Tribunal found the factual matrix proved but held that his failures did not reach the threshold of professional misconduct; he had systems in place, exercised professional judgment based on 20 years' knowledge of the clients, and the case reflected a 'counsel of perfection' by the SRA. The Applicant relied entirely on hearsay documentary evidence and called no witnesses (the FIR was unsupported by a statement of truth). All allegations were dismissed with no order as to costs. The Tribunal also revoked an anonymity order for clients, which was later restored on appeal.