Law Firm Manager Fined £32,500 Over Politically Exposed Person AML Failures

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A Hampshire legal firm manager, Rory Peter Heddle Fordyce, has been fined £32,500 ($43,800) by the Solicitors Disciplinary Tribunal for failures in AML compliance, particularly in handling a politically exposed person (PEP).

Fordyce, who served as manager, director, compliance officer for legal practice, and AML reporting officer for Taylor Fordyce Limited, failed to adequately verify the source of £1.1m ($1.5m) received from a client—Anar Mahmudov, son of Azerbaijani former minister of national security—and £1.9m ($2.6m) from the client’s sister. The Solicitors Disciplinary Tribunal described Fordyce’s approach to source of wealth and funds checks as “rudimentary, piecemeal and naïve.”

Over an eight-year period, Fordyce was also found to have misused the firm’s client account by channeling £638,800 ($860,000) of his own personal expenses through it, including “personal tax issues, personal loan repayments, payments to a former manager of the firm, car repairs and other personal matters.” 

The tribunal also barred Fordyce for five years from acting as a sole practitioner, compliance officer for legal practice, AML compliance or reporting officer, or being a signatory on a client account.

The case shows how poor PEP screening standards can expose firms to heavy regulatory penalties, as well as serious reputational and financial damage, highlighting the importance of recognizing PEP red flags.