Rory Peter Heddle Fordyce

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

Mr Fordyce, an experienced solicitor and the Firm's COLP/MLRO/MLCO, faced five allegations. The Tribunal found allegations 1.1 (inadequate source of wealth/funds checks for a PEP client, Mr Mahmudov, involving receipts of £1.1m and c.£1.9m), 1.2 (using the client account as a banking facility for the £1.1m without an underlying legal transaction) and 1.3 (using the client account as a banking facility for £638,840.95 of his own personal payments over 8 years) proved. Allegation 1.4 (accepting a £250,000 loan from Mr Mahmudov) was not proved as no actual/significant risk of conflict was established and no dishonesty or lack of integrity found. Allegation 1.5 (loan to Client B) failed as Client B was never a client of the Firm. No dishonesty was alleged or found. The Tribunal imposed a Level 4 fine of £32,500, ordered costs of £50,000, and imposed 5-year practice restrictions to protect the public and the profession's reputation.

Duties found breached:

• Non-discriminatory acceptance and cab-rank
• No conflict between current clients
• No improper use of client money
• Not misrepresent regulated status

Aggravating factors:

• Deliberate and repeated conduct over a lengthy period
• Mishandled significant sums of money (client's and his own)
• Experienced solicitor wholly responsible for the misconduct
• Ought reasonably to have known conduct breached obligation to protect reputation of the profession

Mitigating factors:

• Degree of insight into misconduct on allegations 1.1 and 1.3
• Undertook anti-money laundering training and became aware of relevant Warning Notices
• Previous good character with no prior disciplinary findings
• No direct harm caused to any individual client; no actual money laundering established