Ayub Bhailok; Robert Michael Fielding; Bhailok Fielding Solicitors

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

Two partners (Mr Bhailok and Mr Fielding) and their firm, Bhailok Fielding LLP, admitted allegations arising from the firm existing largely to serve Mr Bhailok's property business interests. They allowed the client account to be used as a banking facility (over £17 million in inter-ledger transfers), failed to return client monies promptly (£5m held for 267 days, £4m for 95 days), and comprehensively failed to comply with the Money Laundering Regulations 2017 (no firm-wide risk assessment, no PCPs, no client/matter risk assessments, no AML training records). The SRA withdrew denied allegations including breaches of Principle 6 (2011) and Principle 2 (2019). No dishonesty was alleged or found. The Tribunal approved an agreed outcome, finding high culpability but mitigating factors including no loss and no money laundering risk. It imposed a Level 3 fine of £12,000 (joint and several across all three respondents), costs of £22,000, and practising certificate conditions requiring AML and Accounts Rules training. A special measures application to hold the hearing in private was refused.

Duties found breached:

• Non-discriminatory acceptance and cab-rank
• No conflict between current clients
• No improper use of client money
• Prompt accounting and return of money
• Firm governance, systems and compliance
• Cooperate openly with regulators
• AML and crime-prevention compliance
• Good faith and courtesy to colleagues
• Not misrepresent regulated status

Aggravating factors:

• Respondents were experienced practitioners
• Misconduct continued over a long period of time
• Misconduct was repeated and systemic across a large number of transactions involving large sums of money
• Respondents used their privileges as solicitors to promote Mr Bhailok's self-interest (appearing as more serious purchasers)

Mitigating factors:

• No loss of client funds and no risk of money laundering
• Unusual circumstances - clients were largely the partners, their family and associated companies
• Misconduct involved breaches of compliance standards rather than fundamental tenets of the profession
• Misconduct was unintentional, resulting from an incorrect understanding of requirements
• Long unblemished careers with no prior disciplinary record
• No financial gain from the breaches
• Full cooperation with the SRA investigation
• Remedial steps taken - practice-wide risk assessment, AML policies, template client/matter risk assessments and training records implemented