Clyde & Co, Edward Henry Mills-Webb

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

Clyde & Co LLP and partner Edward Mills-Webb admitted anti-money laundering failures between 2014 and 2019 in shipping escrow transactions for Company A and associated Principals, including inadequate CDD, ongoing monitoring failures, and failures to cease transactions. No dishonesty or lack of integrity was found; conduct arose from carelessness. The Tribunal found the firm's culpability high and placed it in Level 4, applying a notional £50,000 starting point with a 1000% uplift for firm size to reach a £500,000 fine. Mr Mills-Webb was fined £14,000 (Level 3), reduced 15% for delay to £11,900. Total SRA costs of £183,139.25 were apportioned 70% (£128,197.48) to Clyde & Co and 30% (£54,941.77) to Mr Mills-Webb based on relative culpability.

Duties found breached:

• No conflict between current clients
• Non-discriminatory acceptance and cab-rank
• Not misrepresent regulated status

Aggravating factors:

• Misconduct was repeated over a significant period of time with missed opportunities to correct earlier errors (firm failed to 'join the dots')
• Clyde & Co had a previous Tribunal finding (2017) relating to money laundering regulation failures yet did not put adequate measures in place
• Clyde & Co initially sought to blame Mr Mills-Webb and failed to reflect on its own role until a late stage
• For Mr Mills-Webb, he ought to have known he was in material breach; firm being a global prestigious firm bears greater responsibility

Mitigating factors:

• Genuine and complete insight demonstrated, including improvements to systems and controls (Clyde & Co) and 'Reflections' in witness statement (Mills-Webb)
• Co-operation with the SRA investigation; Clyde & Co self-reported in January 2019
• Admissions made (albeit at a late stage)
• No blameworthy motivation; conduct arose from carelessness, not planned or deliberate
• Mr Mills-Webb had no previous findings and provided strong character references
• Significant unjustified delay in the investigation caused stress and potential career limitation to Mr Mills-Webb (15% reduction)