Decision record
Clyde & Co, Edward Henry Mills-Webb
Allegation / charges
Breaches, Code of Conduct 2011, Money Laundering Regulations, SRA Principles 2011
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"]
Codes & rules applied
Duties engaged
- No unlawful discrimination or harassment
- Act in the client's best interests
- Advise objectively, not a mere conduit
- Protect legal professional privilege
- Non-discriminatory acceptance and cab-rank
- No conflict between current clients
- AML and crime-prevention compliance
- Not misrepresent regulated status