A solicitor with a client base in Russia and Ukraine has been suspended for nine months by the Solicitors Disciplinary Tribunal after failing to instate anti-money laundering safeguards.
Natalia Levinzon, admitted in 2007, accepted that she did not have an appropriate anti-money laundering policy in place; that she failed to ensure there was a firm-wide risk assessment; that she did not apply enhanced due diligence measures; that she failed to conduct ongoing monitoring; and that she breached SRA accounts rules.
According to the disciplinary judgment, Levinzon was a partner at Mayfair-based Alexander Dobrovinksky & Partners LLP - which closed last year - at the relevant time. She told the regulator in an interview that there was no risk assessment of the firm or of client matters because ‘they knew 99% of their clients who were family or friends’.
On the question of ongoing monitoring, a statement of agreed facts said that 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 client demographic for the files reviewed by the Forensic Investigation Officer was predominantly Russian and the Ukraine,' the statement said. 'On the matters which Ms Levinzon handed 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,’ it said.
The firm had been subject of a previous forensic investigation in 2015, when Levinzon was issued with a written rebuke and a fine. Levinzon accepted that this was an aggravating factor as ‘previous failings were repeated’.
The tribunal ordered that Levinzon be suspended from practice as a solicitor for nine months from 14 July 2020. It also ordered that she pay costs of £10,000.
The tribunal added that for two years Levinzon cannot be a manager or owner of any authorised body; be a partner or member of an authorised body; hold or receive client money; or be a head of legal practice/compliance officer for legal practice or a head of finance and administration/compliance officer for finance.