That links into another event in the past few days in what seems to be the end of a fascinating affair involving a law corporation in London and money from places and people with far too few vowels in their names for we users of Greco-Latin languages. The Solicitors′ Disciplinary Tribunal has concluded the matter of the Solicitors′ Regulation Authority and Natalia Levinzon. The case was concluded ″on the papers″ with no need for a congregation in a room and no need for travel in an example of how justice systems are working around the problems caused by CoVid-19, even in England where restrictions are far more lax than many other countries. It′s also a ″judgment on an agreed outcome″ i.e. a settlement in which the most severe punishment is avoided, so demonstrating my second point at the beginning. It also ties in with the US regulators′ notice referred to previously.
Note that, amongst the allegations, is that she did not properly identify or perform enhanced due diligence on politically exposed persons.
Over a period of six years or so, Levinzon was a partner with Alexander Dobrovinksky & Partners LLP, which no longer exists. She was, from February 2013, the company′s compliance officer and, from 2018, the company′s money laundering reporting officer.
In the light of that, this is extraordinary: in breach of various, and successive, sets of regulations, ″Between February 2013 and January 2019, she failed to have an appropriate anti-money laundering policy in place … Between 26 June 2017 and January 2019, she failed to ensure that the Firm had a firm wide risk assessment in place…Between February 2013 and January 2019, she failed to provide to employees of the Firm, or to undertake herself, any or adequate training in relation to the money laundering regulations…In around April 2015, she failed to correctly identify clients IT and PT (by virtue of his family connection to IT) as PEPs…Between around April 2015 and January 2019, she failed to apply enhanced customer due diligence measures and enhanced ongoing monitoring in respect of clients IT and PT…″
There are other allegations, mostly of an accounting nature which don′t concern me.