AML Failings Result In Solicitor Suspension

Natalia Levinzon has been suspended for nine months by the Solicitors Disciplinary Tribunal after failing to implement anti-money-laundering safeguards in regards to property transactions she was conducting for a clients in Russia and the Ukraine.

During the investigation, Ms Levinzon revealed to the investigators that the firm – Dobrovinsky & Partners LLP (now closed) – didn’t have risk assessments in place, due to the fact:

“They knew 99% of their clients who were family or friends.”

According to the investigation prior to the tribunal, it was discovered that Ms Levinzon failed in the following areas:

  • not having an appropriate anti-money laundering policy in place
  • failed to ensure there was a firm-wide risk assessment
  • did not apply enhanced due diligence measures
  • failed to regularly conduct ongoing monitoring
  • breached the Solicitor Regulation Authority (SRA) accounts rules

A statement of agreed facts said that Ms Levinzon did not adequately investigate the source of funds for the purchase of certain properties, where there were “red flag indicators including in respect of geographic risk and corporate funding expenditure”.

The statement went on to say:

“The client demographic for the files reviewed by the Forensic Investigation Officer was predominantly Russian and the Ukraine.

“On the matters which Ms Levinzon handled for these clients, funds were used to purchase properties from companies based in Dubai, the British Virgin Islands, St Kitts and Nevis and Cyprus. Those facts… should have led Ms Levinzon to ensure that she conducted adequate ongoing monitoring.”

The tribunal ruled that Ms Levinzon was to be suspended from practicing as a solicitor for nine months from 14 July 2020. She was also ordered to pay costs of £10,000.

The tribunal also ruled that for the next two years, she cannot:

  • be a manager or owner of any authorised body
  • be a partner or member of an unauthorised body
  • hold or receive client money
  • be a head of legal practice/compliance officer for legal practice
  • be a head of finance and administration/compliance officer for finance
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