(unnamed respondent)

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

John Davis, admitted 1978 and principal of Davis-Law Associates, had been fined £30,000 and made subject to practising-certificate restrictions in October 2021 following reckless (not dishonest) regulatory breaches involving Client Account misuse, conflicts, AML failures and unverified correspondence. In December 2025 he applied to remove the restriction preventing him acting as COLP, COFA, MLRO and MLCO. The Tribunal, applying Ebhogiaye, found he had not discharged the burden of proving material change or sufficient rehabilitation, providing only evidence of one COLP course and no supporting documentary or witness evidence. The application was refused, all 2021 conditions retained, and he was ordered to pay costs of £4,320.40 including VAT.

Duties found breached:

• No conflict between current clients
• No improper use of client money
• No baseless or threatened misconduct report
• AML and crime-prevention compliance

Aggravating factors:

• Original breaches were serious and occurred over an extended/protracted period
• Mr Davis ought reasonably to have known the harm that would result
• (2021 findings) actions deliberate and repeated

Mitigating factors:

• No other regulatory history
• Clearly an experienced and capable solicitor
• Cooperation with the original forensic investigation
• No dishonesty and no financial gain found in original proceedings

⚠ figures not found verbatim in the source were dropped: ["review_dishonesty_finding_cue_present"]