Mr Tang acted for a company in the purchase of three flats. The tribunal found that the transaction raised a number of ‘red flags’ indicating possible money laundering that Mr Tang had not addressed, including:

• A deposit into the firm’s client account from an unconnected third party
• A large sum of money being held following completion of the transaction
• A request from an unconnected third party to transfer the surplus proceeds to another party
• An undocumented loan to the purchaser
• The fact that monies were received from outside the jurisdiction and paid out to an account within the jurisdiction.

The tribunal stated that, although minimal harm had been caused, it is ‘incumbent upon members of the profession to raise sufficient questions to satisfy themselves against the risks of potential money laundering concerns arising from any transaction, but particularly in any transaction that contained unusual features such as this one’.

Mr Tang was fined £7,500 and ordered to pay costs of £32,469.86.

Read the judgment

Click HERE to see the full Disciplinary digest December 2017.