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 failings between 2014 and 2019 in relation to shipping transactions involving Company A and associated Principals, including inadequate CDD, ongoing monitoring and failure to cease/obtain further CDD. The Tribunal found the admissions proved. No dishonesty or lack of integrity was found. The firm's culpability was assessed as high and placed in Level 4, with a £50,000 notional starting point uplifted by 1000% to £500,000 to reflect its size and resources as a large global firm and to serve as a deterrent. Mr Mills-Webb's conduct was placed in the higher end of Level 3, with a £14,000 fine reduced by 15% to £11,900 to reflect significant unjustified investigative delay. The firm was ordered to pay £128,197.48 costs (70%) and Mr Mills-Webb £54,941.77 (30%).

Duties found breached:

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

Aggravating factors:

• Misconduct repeated over a period of time with missed opportunities to correct earlier errors
• Firm initially sought to blame Mr Mills-Webb and failed to reflect on its own role until a late stage
• Firm had a previous Tribunal finding (2017) relating to money laundering regulation failures, yet had not put adequate measures in place
• Potential for money laundering could not be discounted
• Firm was a large, prestigious global firm carrying greater responsibility to uphold the profession's reputation
• Mr Mills-Webb ought to have known he was in material breach of his obligations

Mitigating factors:

• Genuine insight demonstrated, including improvements to systems, controls and training
• Co-operation with the SRA and self-report in January 2019
• No blameworthy motivation; conduct arose from carelessness, not planned or deliberate
• Admissions made (albeit at a late stage)
• For Mr Mills-Webb: early admission of errors, no previous findings, positive character references, and significant unjustified delay in the investigation (reduction of 15%)

⚠ figures not found verbatim in the source were dropped: ["unverified_fine_amount=511900"]