Stefanie Anne O’Bryen

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

The Respondent, a sole practitioner and compliance officer (COLP, COFA, MLRO, MLCO) of Watlington Solicitors, admitted eight allegations including failing to keep accurate accounting records, causing client account shortages (£6,079.73 and £3,487.10), failing to have a FWRA and AML policies, making a false and misleading declaration to the SRA regarding a FWRA, failing to conduct adequate CDD/EDD, and failing to carry out due diligence on and supervise consultants (including a disbarred barrister posing as 'Asad Sahi' and a struck-off solicitor posing as 'Edward Elkins'). The conduct was found to lack integrity, but no express finding of dishonesty was made (the false declaration was found careless/unintentional). On an agreed outcome dealt with on the papers, the Tribunal suspended her for 18 months followed by indefinite practising restrictions (barring sole practice, compliance roles, holding client money, and being a signatory on client accounts), and ordered £25,000 costs.

Duties found breached:

• Proper basis for allegations
• Non-discriminatory acceptance and cab-rank
• No conflict between current clients
• No improper use of client money
• Prompt accounting and return of money
• Account for interest on client money
• Supervise staff and delegated work
• Firm governance, systems and compliance
• Not misrepresent regulated status

Aggravating factors:

• Client account shortage repeated between January 2020 and February 2024
• Misconduct continued over time despite two forensic investigations
• Experienced solicitor holding positions of responsibility (sole manager, sole owner, COLP, COFA, MLRO, MLCO)
• Significant harm or prospect of significant harm to a number of clients

Mitigating factors:

• Full and appropriate admissions and co-operation with the SRA
• Over 20 years running a successful practice with a good regulatory record
• Efforts to mitigate effects of Asad Sahi's failures on clients
• Was herself a victim of a fraudster (Asad Sahi/Yawar Ali Shah) who used false identity and was vouched for by other professionals
• Serious illness (breast cancer diagnosis, operations, radiotherapy) and anxiety during relevant period
• No client suffered loss; sufficient office account funds to cover shortfalls