Tribunal fines firm manager and imposes five-year practice restrictions over serious AML breaches
A veteran solicitor has been fined £32,500 and banned from holding senior positions in law firms for five years after failing to carry out adequate anti-money laundering (AML) checks on a politically exposed client.
Rory Peter Heddle Fordyce, admitted in 1979 and formerly a manager and director at Hampshire firm Taylor Fordyce Limited, was found by the Solicitors Disciplinary Tribunal (SDT) to have breached key AML regulations when acting for Anar Mahmudov, the son of Eldar Mahmudov, Azerbaijan’s former national security minister.
The breaches related to two high-value transactions worth £1.1 million and £1,946,603. The tribunal ruled that Fordyce failed to take sufficient measures to establish the true source of Mahmudov’s wealth and funds.
Embed from Getty ImagesTwo further allegations were upheld: that he had improperly used the firm’s client account as a banking facility for the £1.1 million transaction between January and April 2014, and that between May 2014 and January 2022 he had used the account to process his own personal payments — a breach he admitted in full.
However, the SDT dismissed claims that Fordyce had borrowed money from Mahmudov for his or the firm’s benefit, and that he had provided a £138,200 loan to another client.
In his own admissions, Fordyce accepted that his AML checks were insufficient, saying that “on reflection” the steps he took “were not sufficient to comply with the MLRs” (Money Laundering Regulations). He maintained that the failings were unintentional and told the tribunal he had since undertaken intensive AML training as a “learning point.”
The SDT’s judgment was damning, describing his due diligence as “rudimentary, piecemeal and naïve.” The tribunal concluded that Fordyce had “prioritised the transaction over his regulatory obligations” and that his failures were “sufficiently serious, culpable and reprehensible.”
Representing Fordyce, Michael Uberoi argued in mitigation that no client funds were misused, no actual money laundering occurred, and no third party suffered harm. He emphasised that Fordyce had not been motivated by personal gain.
The tribunal accepted that there was no evidence of laundering and that Fordyce had shown “a degree of insight” into his misconduct. However, it noted that his actions arose from placing expediency and client convenience ahead of compliance. He had, it said, “subordinated those duties to his desire not to jeopardise the transaction for an important client.”
As part of his sanction, Fordyce will be prohibited for five years from acting as a sole practitioner, manager, or owner of any authorised or recognised body. He will also be barred from taking on compliance roles, including compliance officer for legal practice (COLP) or money laundering compliance officer (MLCO), and from acting as a signatory on any client account.
In addition to the fine, Fordyce was ordered to pay £50,000 in costs.
The case underscores the heightened scrutiny placed on law firms when dealing with politically exposed persons (PEPs) — clients who, due to their political connections, present a higher risk for potential money laundering. Regulatory obligations require firms to carry out enhanced due diligence in such cases, including verifying the source of funds and wealth.
For Fordyce, more than four decades in the profession ended in a damaging public censure, financial penalties, and strict limitations on his future legal work — a cautionary tale of how failing to meet AML duties can derail even the longest legal careers.