Decision record
Andrew Gordon Walker
Allegation / charges
Agreed Statement of Facts
Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision
Andrew Gordon Walker, a securities lawyer who acted as corporate solicitor, director and officer of P Corp., admitted misappropriating roughly $86,456 of client funds to buy company shares for himself and two others without authorization, falsely recording the funds as exploration expenses in interim financial statements, misleading the client that the money remained trust monies, failing to correct the record with the Exchange, engaging in conflicts of interest through an undocumented 'loan,' and participating in a scheme to divert 'finder's fee' shares he knew he had no entitlement to. He admitted professional misconduct, conduct unbecoming and incompetence. Rather than a formal disbarment order, he gave undertakings to terminate his membership effective November 28, 2008 and not seek reinstatement for at least 10 years, with restrictions on practising elsewhere. No fine or costs figures were stated, and the tribunal made no express finding of 'dishonesty' in the text provided (though misappropriation was admitted).
Duties found breached:
- No conflict between current clients
- Handle inadvertently received material
- No improper use of client money
- No improper fee-sharing or partnership
Aggravating factors:
- Respondent acted simultaneously as corporate solicitor, director and officer of the client company
- Personal benefit obtained from misconduct
- Concealment from the fourth director (PC) and the company
- False documentation/records and misleading statements to the client, the Exchange and the Law Society
- Parallel regulatory proceedings before the TSX Venture Exchange and BC Securities Commission
Mitigating factors:
- Admission of the facts and misconduct through an Agreed Statement of Facts
- Admitted there was 'no possible justification' for the Finder's Fee Shares scheme
- Entry into undertakings and cooperation with resolution