George Fahim Sa’id

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

Mr Sa'id, a sole practitioner, was alleged to have failed to carry out adequate enhanced due diligence and to have adequate risk-management systems for two property purchases (the London Hotel and the London House) connected to a wealthy family from a high-risk third country, contrary to Regulations 33 and 35 of the MLRs 2017. His electronic PEP search failed to identify that a family member (the Minister) was a Politically Exposed Person, so EDD was not triggered. The Tribunal found the underlying facts proved but held that his failing did not reach the level of professional misconduct/breach of the Principles or Outcome 7.5, describing the SRA's case as a 'counsel of perfection.' The SRA relied only on hearsay documentary evidence and called no witnesses. All allegations were dismissed with no order as to costs. There was no allegation or finding of dishonesty. The Tribunal also revoked earlier anonymity orders (later reinstated on the SRA's LPP appeal to the High Court).

Mitigating factors:

• Long-standing (over 20 years) business relationship with and knowledge of the client family and the source of their wealth
• Reliance on the Veriphy electronic search system which was believed to reveal foreign PEPs
• Failure was a single, inadvertent and unintentional oversight rather than deliberate or careless disregard
• Respondent had a firm-wide risk assessment and CDD systems in place; SRA's own July 2017 AML assessment found no issues
• Respondent took steps to strengthen and improve his AML systems after the matter came to light