Decision record
(unnamed respondent)
Findings — machine-extracted (anthropic-batch:claude-opus-4-8); verify against the decision
Francis Mathew applied under Rule 18 to remove an indefinite restriction preventing him from holding compliance roles (COLP/COFA/MLRO/MLCO) without SRA permission, imposed in October 2024 alongside a £25,000 Level 4 fine for serious Accounts Rules and money laundering compliance failings (including a reckless inaccurate declaration to the SRA; no dishonesty found). The Tribunal held there was no time bar on such applications and that an appeal was not the only route. It found the restriction otiose because SRA permission for compliance roles was already required under the regulatory framework, so it was no longer necessary to protect the public or the profession's reputation. Application granted; applicant ordered to pay agreed costs of £2,399.
Duties found breached:
Duties engaged
- No bribery or improper gifts
- Personal probity and fitness to practise
- Uphold public trust in the profession
- No unlawful discrimination or harassment
- Act in the client's best interests
- Advise objectively, not a mere conduit
- Handle inadvertently received material
- Segregate client money
- No improper use of client money
- Accounting records, reconciliation and reports
- Cooperate openly with regulators
- Self-report to the regulator
- Report serious misconduct of others
- Not misrepresent regulated status