In one, Mr Purnell wrote: “We do not do much work in relation to these types of securities, so are not in a great position to assess the plausibility of the transaction.”
The SDT said: “A proper investigation of this matter would have led to establishing that the transactions were, at best, dubious. By acting as escrow agents… [they] might have been seen as lending credibility to the transactions…“
Moreover, there were examples of [Mr Purnell] and [Mr Duffy] recognising this risk, but apparently failing to take adequate actions in response.”…
The ruling exposed shortcomings in the firm’s procedures at the time – while Clyde’s risk register highlighted the dangers of money laundering and potential to breach the Solicitors Accounts Rules when providing escrow facilities, it was not available to the firm as a whole, and Mr Purnell and Mr Duffy were not aware of it.