Louise Elizabeth Sutherland

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

Duties found breached:

• Accounting records, reconciliation and reports
• Honesty
• No improper use of client money
• Not misrepresent regulated status
• Prompt accounting and return of money
• Proper basis for allegations
• Truthful, non-misleading advertising

Aggravating factors:

• Premeditated/calculated course of conduct
• Included deliberate attempts to conceal the true position through misleading ledger narratives and fabricated fee notes
• Serious and sustained breach of the Accounts Rules at the extreme end
• Substantial sums involved across many client files