HMA v Housley and others

THE INVESTIGATION AND TRIAL LEADING TO THE CONVICTION FOR MONEY LAUNDERING IN JANUARY 2013

Richard Housley

OUTLINE POINTS

• HMRC gave £38Million of taxpayers’ money to the company QTech in VAT ‘repayments’ which were not due.

• HMRC expected QTech to turn over £250,000 in a year but paid out on a turnover of £22Million in the first quarter.

• HMRC went on to give the QTech fraudsters most likely over £100Million in ‘repayments’.

• For 10 Years HMRC paid out up to £800Million per month, nearly £10Billion per year, to carousel VAT fraudsters.

• I was sentenced to 4 years imprisonment for handling £1.3Million, involving 4 legal transactions in total, when I knew nothing about carousel fraud, the QTech fraud or had even heard the name QTech.

• Michael Voudouri pled guilty to laundering £10Million through QTech in a deal which allowed his wife and father in law to walk free and in which he incriminated me.

• Despite him being a clear flight risk, the deal allowed Voudouri bail and he fled to Cyprus.

• There were many other major players in the QTech fraud and other major carousel frauds. None were prosecuted.

• The Crown prosecutor wanted to abandon the case against me but his superiors refused.

• The authorities controlled the press coverage of my case, releasing inaccurate and deliberately misleading material.

THE STORY

Introduction

I have tried to write this as a summary of what has happened. In the attempt to get the main points across in such a complicated case, it is unavoidably lengthy and the content will, of course, be of little interest to most. All I would ask is that if you don’t feel like reading it through, don’t judge me on what you have heard about the case or the nonsense written in the newspapers after the trial.

I have also heard of many comments made over the past few years, some even from individuals in prominent positions in the justice system (who should know better than to jump to conclusions in the absence of knowledge of the detail of the case), suggesting that it should have been clear to me in my position as a solicitor, that criminal offences were being committed by my clients. If you are one of those commenters and you have got this far, maybe you could do me the courtesy of continuing to read to the end.

When reading, there may be questions which spring to mind to which there are no obvious answers. This is simply because I cannot put everything in. However, I have answers to all questions and these have not changed since the first time I was asked the questions. One of my counsel said at the start of the trial that I had “a valid answer to everything that had been raised in the disclosure”.

For the avoidance of doubt, I have neither embellished the story nor deliberately left out anything which goes against me. All the facts can be confirmed.

It should also be borne in mind as the story unfolds, that a jury was supposed to grasp what was going on at every stage of the trial.

Michael Voudouri, Cortec and QTech

I acted for Michael Voudouri who was involved in two major carousel VAT frauds in the late 90s/early 2000s. The first was perpetrated through a company called Cortek and the second through a company called QTech. He was jailed for four years in 2004 for the first of these frauds. There were at least two other major players (not the relatives of Voudouri mentioned later) involved in the second fraud, which was by far the larger of the two but, despite there being no doubt about the guilt of all three at the end of my trial, any plans by the Crown to prosecute the other two had been dropped much earlier ‘for evidential reasons.’ No one has ever explained why Voudouri was prosecuted for only money laundering and not fraud in respect of the QTech carousel and why both fraud and money laundering charges were never pressed against the others.

When I acted for Voudouri in 2002/2003 I had no knowledge of either of his crimes. I did not even know the names of the companies involved until 2009 when I was served with the petition in the case against me. I handled money for him as I did in the normal course of my business as a solicitor but in his case the money turned out to be proceeds of crime (POC) from the second VAT scam (QTech). The money did not actually come to me direct from QTech but through other companies controlled by Voudouri. I tried to explain to HMRC on a number of occasions that I was only doing my job but they were obviously intent on getting Voudouri in any way that they could and the possibility of nabbing a solicitor at the same time would have been attractive to them.

The investigation went on for some eight years during which time HMRC showed an attitude of neither understanding my position nor wanting to understand it and, by the time the they were ready to go to trial, the situation was that either (a) they were still convinced in their own narrow view of the situation that I was guilty or (b) they had dug themselves in so deeply that they had to continue with a prosecution and/or (c) they thought they may as well take a ‘shot to nothing’ on getting a guilty verdict.

The Trial

The trial, in which I was one of five accused of money laundering, was eventually set for October 2012. At the eleventh hour Voudouri negotiated a plea of guilty on the basis that the Crown would restrict the charge against him to around £10Million and that they would allow two of the other accused, his wife and his father in law, to go free. During the subsequent trial it was proved beyond any doubt that Voudouri had been involved in laundering at least £50Million and that his wife and father in law were also guilty of serious offences. So, three of them were out of the trial at that point and the case continued against Caroline Laing, an accountant who had worked for Voudouri as a bookkeeper and IT consultant, and me. Meantime Voudouri was released on bail to return for sentencing one month later.

Obviously as part of his deal, Voudouri then made a ludicrous statement to the Crown, saying that Caroline Laing and I were aware that the money was dirty. He said that “Richard Housley had been introduced to him as a solicitor who could move money for a commission” and he went on to say such things as, his wife (Voudouri’s) was “completely unaware of his business dealings” and “someone must have forged her signature” on bank and other documents. It was obvious that the takers of the statement, presumably HMRC, had not questioned what he had said to any degree but were quite happy to rely on it.

Voudouri then failed to turn up at the sentencing diet, having fled to Northern Cyprus where his family subsequently joined him. The question has to asked …. why was he released on bail when he had, not long before, completed a four-year sentence for the Cortek crime and was about to go away for something in the region of ten years for the QTech crime? He was an obvious flight risk. HMRC and/or the Crown must be responsible for the cost and effort required over the two years it took to bring him back to Scotland.

As it happened, the Crown attempted to use Voudouri’s statement against me at a late stage in the trial but it was deemed to be unacceptable by the judge. Nevertheless, the existence of such a statement obviously gave momentum to the prosecution.

The Evidence

The trial lasted for three months, during which time the Crown neither led any direct evidence nor tried to lead any direct evidence, of me knowing that the money which I handled was ‘dirty’. The judge confirmed in his charge to the jury that there was no such evidence. There was clear proof that Voudouri his partners and his family were all guilty of both fraud and money laundering and, along the way, they had pulled the wool over the eyes of HMRC, major banks, other solicitors and accountants and many individuals.

The money which I had handled was confirmed to be POC, a fact which I was later happy to acknowledge but something which I did not know or suspect at the time. However, although it was POC, it was clear that it had been ‘cleaned’ in the normal sense of the expression, long before it was given to me as it had passed through regulated banks, often more than once, on its way to me. Not only that but it was also clean from day one as it had come from the QTech carousel VAT scam, that is, it had been given to Voudouri and his partners in the first place by HMRC in VAT repayments and there was no need to clean it in the sense of getting it into the banking system. Any bank would accept money which originally came from HMRC.

The whole affair started by HMRC writing cheques for £38Million to QTech over a short period of time in respect of repayments of VAT which they considered to be due. After a period of ‘trading’, HMRC thought that there may be something fishy going on so they started to look at QTech in closer detail and, by the time they served a notice on the company “for the immediate payment (which was of course repayment) of the sum of £38million pounds”, the money was long gone. This was a company which, from the application for registration for VAT, examined by HMRC, expected to have a turnover of £250,000 per annum then went on to disclose a turnover of £22Million in the first 3 months of trading. The initial repayment of VAT was routinely made on the basis of that £22Million turnover with no concerns raised by the application estimate having been only £250,000.

That was just for starters. It is reckoned, and there was evidence of it in the trial, that the fraudsters continued to ‘carousel’ and eventually took HMRC for hundreds of millions. There was such jaw dropping evidence as one of QTech’s directors, losing 20Million dollars over a short period of time at the Bellagio Casino in Las Vegas. He paid for company jollies to Las Vegas for all his staff and friends, travelling business class and staying in luxury hotels. There was also his spending of some 2Million dollars on a yacht in Miami and the spending by his wife and Voudouri’s wife of over 1MIillion dollars on jewellery alone, on one trip to Switzerland.

Carousel VAT Fraud

We also learned at the trial that carousel VAT fraud had become a major industry around the year 2000 although it was something which the average person, or average solicitor for that matter, knew nothing about. Expert evidence was led by HMRC that, from the late 1990’s until around 2008, HMRC were losing up to £800Million per month (approaching £10Billion per annum) to carousel VAT fraudsters until they managed to get some control over the situation. Having given them the money in the first place, they could then not catch the baddies for BILLIONS each year for some ten years but they expected me to do so in 2003 for the amount I handled.

My Involvement

During the years of 2002 and 2003, acting in my capacity as a solicitor, I carried out property and investment transactions for companies related to Voudouri where the sums which passed through my client account amounted to just over £3Million. Although this would obviously sound like a very large amount of money to the jury, it would not be unusual for me, as a solicitor, to regularly handle millions of pounds in one month, sometimes in one week and sometimes over £1Million in the one transaction, never mind over a year or two. My firm’s professional indemnity level for a single transaction was £3Million. Almost all of the £3Million connected to Voudouri was received prior to the Proceeds Of Crime Act 2002 coming into force in 2003. It was proved at the trial that it originated from QTech although it was acknowledged that HMRC themselves were unable to establish it was part of the QTech fraud until 2008, some six years after I received it.

Presumably because the money was received prior to the POC Act coming into force, I was not prosecuted in respect of that £3Million but the Crown led evidence of it going through my firm’s bank account on the basis that there were some aspects of the pattern of the payments that they alleged were “unbusiness-like”. I was prosecuted in respect of (and found guilty of) handling money during the selling of/granting of security on, properties in 2004 which were bought using part of the money received in 2002/2003. This involved 3 transactions totalling a value of around £900,000 of that £3Million and I was also found guilty of handling POC in respect of another sale in the amount of around £400,000, that sale being of a property which was bought in 2001 by another firm of solicitors.

What the Crown was saying was that I either knew that the money was POC or I was (not just should have been) suspicious of these transactions simply because of the nature of them and because Voudouri was involved. This was despite the fact that the money was received before the POC Act came in and the obvious effect that that would have had on my mind-set together with the fact that I knew nothing about Voudouri other than that he genuinely seemed like a well-off client who was investing in legitimate deals. The conviction was on the basis that I was allowed to regard the money as legitimate in 2002/2003 but not to regard it (or the properties bought with it) as legitimate in 2004 even although nothing had happened in the interim period to influence my view on legitimacy. Another solicitor, in 2001, obviously regarded the £400,000 property to have been bought with clean money.

It should also be considered that, while the POC Act came into force at the end of February 2003, the regulations following thereon which applied to solicitors, did not come into force until 2004 and solicitors did not start training on those regulations until after they came in. So, I was being judged on a new law which had not been properly introduced to the profession at the time of my ‘crime’. Furthermore, the jury decided that I was suspicious in respect of the handling of money relating to the QTech fraud in 2003/4 when, as I have said, it took HMRC with all their resources from around 2001 until 2008 to realise that that money was indeed from that fraud and then prove it. So, while HMRC let QTech trade under their noses and initially gave them £38Million …. then a lot more of taxpayers’ money, I alone was supposed to have suspected that Voudouri was involved in criminal activity.

In addition, not only did other Scottish solicitors act for Voudouri, they also acted for QTech, handling substantial sums of money which came directly from that company. However, no other solicitor was prosecuted. And on top of that, one of the smaller branches of the Bank of Scotland in Glasgow handled all £38Million of the initial batch of QTech VAT money and the manager was given the Manager of the Month or similar awards on a number of occasions.

The main thrust of the evidence which the Crown attempted to lead against me was that I was very close to Voudouri and therefore would have known about all that he had been up to. They started by trying to suggest that I was ‘running around’ with him and his friends, meeting them on a regular basis and socialising with them. I do not know where they got this idea from as there was never any evidence of it. I suspect it was something which HMRC wanted to believe and thereafter, as time passed, it developed in their minds from theory to accepted fact without proper justification. Either way, at the trial, it was established that I had had no more than a normal business relationship with Voudouri, seeing him maybe a few times a month then not seeing him for months.

I should also confirm that, in early 2003, I accepted a nominal appointment as a director in one of the companies which Voudouri ran and the Crown used evidence of this against me. However, in court, forensic accountants (acting for HMRC, who were called as prosecution witnesses) confirmed that that company had been properly formed and was trading legitimately, with all due payments being made in respect of tax, NIC and VAT. The HMRC accountants described it as “a properly run company”’. It also had had a clean audit by independent chartered accountants during my time as a director.

Furthermore, around this time, I was a director/trustee of several companies/charities. These are common appointments for a practicing solicitor. Indeed, despite all that happened, I still continued to be a trustee in those charities after my conviction which I hope says something about what those who know me think of all that has happened.

It has to be asked why anyone in my position would take a directorship in a company which they knew or suspected was actively laundering money? I am far from perfect but I am not stupid.

And while on that line of thought, why would I openly put money which I clearly knew or suspected was dirty, through my client account (for no motive or benefit, in plain sight, with no attempt to disguise it in any way) for the many who were likely to examine the account, to see?

The Law Society - Mr Cumming

The Law Society of Scotland is obviously the regulatory body for all solicitors in Scotland. Any training of the profession under the POC Act is its responsibility. Solicitors are obliged to follow its advice and should be protected by following it. In early 2003, the Society carried out a routine audit of my firm’s accounts and saw all of the entries which related to the Voudouri companies. After the audit, amongst other routine points which are always raised at audit, Leslie Cumming, the Chief Accountant of the Society, raised queries regarding some of the Voudouri related accounts and file entries. I answered the queries and thought that the Society was happy with my responses.

During these discussions, Mr Cumming confirmed that I should consider my position in respect of the monies received, given that the POC Act had just come into force and there would be requirements under same to ensure that solicitors obtain additional information on their client companies with a view to establishing firstly, the identity of the beneficial owner of the company and, secondly, that any company structure was not unduly complicated. In this particular case, he suggested that it was also necessary to check these points as the companies were registered offshore. I responded that I was satisfied on both points in that I already knew the details of the beneficial owners and the company structures were not complicated. I had already checked the money laundering requirements for offshore companies with his colleague Bruce Ritchie as I will explain later.

At the end of these discussions Mr Cumming did not say that he thought these entries were suspicious and should be reported under the POC Act. This should be considered against a background of the Law Society subsequently clarifying that it will tell you when you should be suspicious (one instance is in the January 2007 edition of the Journal of The Law Society of Scotland). Furthermore, during a later discussion with Cumming’s colleague Bruce Ritchie concerning the clients, I was told to report a certain (relatively minor) matter. Again, I will come back to this.

At the trial, Mr Cumming, who was called as a prosecution witness, said that, at the time of 2003 audit, his correspondence with me was actually an attempt to alert me to the fact that the entries were sufficiently suspicious in his eyes as to warrant a report. He used the expression that ‘you can lead a horse to water but you cannot make him drink’, the inference being that he was trying to assist me but could not tell me to report. However, as I have said, I did not take this from what was said in the correspondence with him after the 2003 audit.

Also, if he thought it to be the case, why did he not simply tell me that these entries in themselves were so suspicious that they merited reporting? When questioned about this in court he said that he was unable to do so because his department was one charged with compliance rather than advice and there was a clear distinction in his eyes regarding these two functions. It was the role of his colleague Mr Ritchie and his department to give advice. He said that there were ‘Chinese walls within the Society’ and there would never be any discussion between himself and Ritchie on such an issue.

Since the trial, I have discussed this point with a number of solicitors and every one of them has never been aware of any such distinction. The Accountant’s department often gave advice on all sorts of issues, including money laundering.

The fact is that, after the audit, my reaction to what Mr Cumming had said to me was based on what I knew about the clients and what he had asked me to consider about ownership and structure. He should therefore have accepted that as a genuine response and said so in court. Alternatively, he should have told me at the time that, in his eyes, the payments were just so ‘unusual’ (his word) that my reporting was the only solution. However, that would never have been likely given that one of his 2003 letters to me said …. “in circumstances where payments are unusual, you have to be happy that you have checked........”. So, by saying this he was leading me to believe that there was nothing wrong with the payments in themselves, that is, unusual payments (or ‘unbusiness-like’ as the prosecution chose to describe them for maximum effect) are acceptable as long as certain other checks are applied. If anything, this would naturally lead me away from any suggestion that these payments should be reported.

And, of course, whatever Mr Cumming was thinking, it has to be remembered that he would have been looking at the situation from his point of view as an official of the regulatory and training body for solicitors, someone who had been given new information on an Act which had just been passed but which information could not be properly passed on to the profession until much later. I obviously had a completely different mind-set as the solicitor ‘at the coalface’. His thinking would surely have been influenced by both the advantage he had in respect of his knowledge of the incoming legislation and the limitations of his knowledge in respect the client.

It is ironic that the money I handled did then turn out to be POC. From his attitude in court, Mr Cumming had obviously convinced himself that he was one who saw through it all and was patting himself on the back for his cleverness. The truth is that, had he concentrated less on revelling in his role as enforcer behind his Chinese walls and more on fulfilling his recognised obligations as Chief Accountant, he could have had a proper discussion with me which would have resulted in either (a) him agreeing that there was nothing to report or (b) him telling me to report. In the event his handling of the situation helped ensure that any opportunity to either report or obtain his approval to not doing so, was lost and I was left with a problem.

Also, if his role was purely one of compliance as opposed to advice, why did he try to ‘lead me to water’? This was an admission that he was attempting to advise me and by doing so he would be breaching his own Chinese walls.

Of course, in court, the analogy of leading the horse to water gave the impression that he thought that I had done something wrong.

Furthermore, as an enforcer, why did he not take action against me as someone who had not complied with the law? Had I, for example, used clients’ funds for my own purposes or had no ML procedures in place at all or had not kept proper accounting records, he would have taken disciplinary action against me under the Law Society’s regulations. It was a requirement of both the law and those regulations that I report anything which a solicitor should normally regard as suspicious but he stood by and watched as, from what he was saying, I both acted contrary to the regulations and broke the law.

Having had the opportunity to properly consider what happened during his testimony, I would have liked to have been able to ask Mr Cumming when he first decided that there should be Chinese walls within the Law Society. Was it before the time of the 2003 audit? Or was it nearer the time when he was due to give evidence at my trial?

Counsel’s Fees

In the autumn of 2004, after I had finished acting for the clients in respect of the property transactions and Voudouri had gone to prison for the first of the two frauds, my firm received £28,000 in respect of fees to be passed on to a senior counsel who was defending of an action which was continuing against Voudouri’s father in law’s company for confiscation of assets under the civil POC legislation. (As an aside, I should say that my court colleagues were handling the case, this running contrary to the allegation from the Crown and reports in the papers, that I was trying to hide Voudouri and keep his business to myself). The £28,000 came from an account in the name of Voudouri’s daughter.

I carried out the normal money laundering checks and found that the money came from National Westminster Bank, obviously both a major and regulated bank which has its own money laundering procedures. Again, I will come back to this.

The HMRC Investigation

Around the same time (autumn 2004) I was made aware that HMRC were looking into my personal affairs, in particular, asking how I had financed a car which had been legitimately bought by my firm. For the first time I realised that there may be some question of accusations being made against me personally so I phoned HMRC’s ‘confidential line’ to ask why the enquiries were being made and to say that I would be happy to explain my position as I had nothing to hide. (Contrary to suggestions during the trial disclosure, this was not an attempt to accuse my client and I never gave my agents instructions at any time to offer to testify against him. I simply had nothing to hide and my telling the truth would have helped confirm that both the client and I had followed the proper ML procedures in each transaction).

My call was not returned, despite a detailed message on the subject matter being left. I called a second time and was told that someone would call me back. Eventually someone from HMRC did, ‘playing the daft laddie’ by claiming that he knew nothing about Voudouri (probably one of biggest prosecutions on their books at the time) but asking what I “wanted to report”. I said that I was concerned that I was being investigated and would be happy to sit down with them to go over matters in detail. The caller said he would get back to me within a few weeks but did not. I then called again and could not get a hold of him so I faxed him saying that I was trying to cooperate.

I heard nothing further until some two months later when a squad of HMRC officers wearing body armour carried out early morning raids on my house and my office. They blocked the entrances to my driveway and came through my house door at 8am. They prevented my wife and children from going to school until my cars were searched. They were at my house for some five hours and my office for some nine hours. The raids caused extreme distress to my family and mayhem at the office. At the end of the searches they only took away office records which I would have made available had they agreed to interview me. There was nothing of significance in my house.

I later learned that, as part of the investigation, raids were carried out simultaneously on a number of locations.

Following these raids, I was unwell for a time but with the help and reassurance of friends and family, I managed to get back on my feet relatively quickly. At the trial the prosecution attempted to suggest that my going downhill was because I had been ‘found out’ but it was simply the enormity of someone who had never been in any trouble in his life, being hit with the accusation of being actively involved in a major crime and being attacked in such a vicious manner, particularly when his offers of openness had been rejected.

The Law Society - Mr Ritchie

I earlier mentioned Bruce Ritchie, who was the Director of Professional Practice at the Law Society of Scotland. To properly introduce him to the story, I have to go back to almost the beginning of the whole affair, to May 2002, when I first made contact with him concerning the clients. As a senior advisor on matters of professional practice, solicitors had always regularly contacted him to ask for advice on situations arising in transactions. On this occasion I was dealing with one of the early Voudouri transactions and I just wanted to ensure that I was doing the right thing in respect of the money laundering regulations which were in place at that time (pre the POC Act), given that the company was registered offshore.

So, I called Mr Ritchie and went over in detail with him, what I had to do to satisfy the money laundering requirements. He pretty well confirmed what I thought would be the case but, as with many such situations, it was best that I had his confirmation. I noted the details of the telephone conversation on the file and carried on. During his evidence in court, although he could not recall the detail of the 2002 telephone conversation, Mr Ritchie confirmed that the file note reflected the kind of discussion which would have been expected to take place in these circumstances and which was proper practice in respect of ensuring compliance with the Law Society’s rules.

Then, moving forward again to the time of me calling HMRC in late 2004 to ask why they were looking into my affairs, I again contacted Mr Ritchie for guidance and we met, on his suggestion, at the Law Society offices in Edinburgh. At the meeting I went over the whole history of the matter, telling him about the transactions up until the Law Society audit in 2003 in outline terms, less detail being required there as the Law Society had already seen the files for those. I then went on to tell him in detail about everything which happened from 2003 onwards, including all four of the transactions handled in 2004.

Mr Ritchie asked me to confirm what documents I had seen in respect of the money laundering rules and the detail of what exactly happened in each transaction. He considered the money laundering issues arising from them all as we went through them and ‘crossed off’ each requirement as he heard what action I had taken. He was obviously aware at this time that Voudouri had gone to prison for VAT fraud.

I also told him about the £28,000 received in respect of counsel’s fees and he told me that, on balance, it would be best to report this on the basis of the Voudouri connection and the fact that the daughter may have been rather young to have such a large sum of money. He did not think that there was any other aspect to be reported. I sent the report as instructed although I understand that no action was taken by the authorities on receiving it.

At the trial Mr Ritchie’s evidence started with the declaration that, before I went to see him, he had no previous experience of me or my firm. None at all. This was despite my having spoken to him on a number of occasions over the years. I was also a partner in the firm for twenty-five years and it is just impossible that he “didn’t know the man from Adam” as he put it in an early attempt to distance himself from me.

When he was questioned about his conversation with me in 2002, he said that he had a considerable number on enquiries from solicitors in each year and would never be able to remember the specifics of each one but, as I have said above, he was happy that my file notes supported a position of having fully complied with the money laundering rules.

However, when questioned about the 2004 meeting, he said that he could only recall me raising a query about counsel’s fees when the truth was that I had discussed the whole affair with him. Why would I go to him for advice and only tell him about the fees? He also confirmed in court that I had gone to him because HMRC were looking into my affairs, asking questions about a “rather expensive car which he (I) owned”. Why would HMRC be looking into my personal affairs in such a way simply because I had received a fee from the clients? That does not make sense and Ritchie would have immediately queried it at our meeting.

The facts are that HMRC were looking into my affairs because I had handled larger sums of money for Voudouri and I had become a director in one of the companies, and it would have been impossible for me to brush over this at the meeting.

So, in court Mr Ritchie could not recall the fuller detail. However, he was able to recall that the meeting with him was “lengthy” (it lasted for about two hours) and also the bits about the car and the fees. It would not, of course, take me anything like a couple of hours to tell him that my firm was defending an action, I had received money for fees from the clients and I wanted to discuss whether I should be suspicious in that respect alone. So, what did I say to him for two hours? I told him the full story. (In hindsight, I should have insisted on his written notes of the meeting being produced during the trial).

As a result of his testimony, Mr Ritchie, in saying that he could only recall the discussion about the fees, undermined any protection that I should have had as a result of discussing the whole affair with him.

It was also the Crown’s suggestion that I had only gone to Ritchie to cover my back, knowing all along that the money had been POC. On thinking that through, I would have expected someone in that situation to have just dug in and said nothing. If I had indeed known or suspected from early on that all the funds that I had received were POC, why would I have gone to the Law Society at this late stage? Having taken the earlier view that I should say nothing, any openness at that point would surely have been more likely to prejudice me than help me. Indeed, I did want to ‘cover my back’ but only from the point of view of making sure that I had done everything properly and it was only when I heard that HMRC were looking at me personally that I thought “Hold on- have I made any mistakes here? I’d better just make sure”.

So, by the end of this affair, I had openly discussed my involvement with Voudouri on three occasions with two senior officials of the Law Society. On each occasion I did exactly what they told me to do.

My counsel was, of course, allowed to cross examine both Cumming and Ritchie but there was only so much that could be achieved by this (trials, particularly ones where there is so much complex detail to consider, move at such a pace that it impossible to continually discuss with counsel in the moment, changes to the line of questioning of a witness). Again, with hindsight, I would have liked to have pressed both of them on the points mentioned above. Their interpretation/memory of the situation must have influenced the jury. To what extent we will never know. The point is that a proper recall and interpretation of what had happened (rather than the pomposity and the covering of backs that was displayed) could have had a significantly positive influence in my favour and could even have affected the Crown’s ability to continue with the prosecution from that point on.

It is hugely ironic that, in 2007, the Law Society published in their Journal, the article referred to earlier, under the title of ‘Hung Out To Dry’, the Society therein warning about how failure to consult with and follow the advice of its staff regarding situations arising under the POC Act, could leave members as just that. I had first spoken to Ritchie some five years earlier, corresponded with Cumming some four years earlier and I had the two-hour meeting with Ritchie over two years earlier.

On each occasion I discussed the transactions openly and followed the advice given.

Can anyone reasonably suggest that these are the actions of someone who is either actively involved in money laundering or suspects money laundering but wants to keep it to himself?

The Supervisory Authority

The POC Act (section 330 (8)) states that the court must take into account whether the accused has followed the advice of any supervisory body approved by Treasury under the Act, in the coming to a conclusion on whether a crime has been committed. The judge recognised this early on. He made a specific point of telling the court, in the absence of the jury, that he was bound to refer to it in his charge to the jury at the end of the trial and, accordingly, he would be doing so. As I have said the Law Society is the regulatory/supervisory body for Scottish solicitors. However, when it came to charging the jury, the judge did not mention the point.

Immediately following his charge, my counsel approached him in chambers to ask why he had not made the reference. His answer was that, during his evidence, Mr Ritchie had mentioned that the Law Society had not actually made an application to register in terms of the POC Act as supervisory body, Ritchie’s understanding being that there was no formal requirement to register. As a result, on the basis that the judge did think there was a requirement to register (we still have no idea where he got this from), he had changed his mind about making a reference to the jury.

So, I did not receive the benefit of the provisions of section 330 of the Act. Furthermore, my counsel had completed my defence on the presumption that, from what was said earlier, the judge would make the point in his charge.

It has since been established that the Law Society is not required to register as a professional body under the POC Act and has always been listed in Part 2 of Schedule 9 of the Act as the professional body acting as a supervisory authority in relation to Part 7 of the Act concerning money laundering, that is, it has been approved by the Treasury.

This issue was later raised as one of a number of appeal points but it was not entertained by either the appeal judges or the Scottish Criminal Case Review Commission. Their answer was that there was plenty evidence in the trial about the following of money laundering procedures so there was no need for the judge to say anything in his charge. Our point is that there is a significant difference between the jury deciding what, off its own bat, to consider and it being told by the judge what it must consider. The judge, in his taking the time to make specific reference to it early in the trial, clearly regarded the clause as one which could have a bearing on the jury’s thinking. If the point was always going to be of no significance, why specifically raise it in such a way?

Surely then this point should have been properly addressed in an appeal.

The Verdict

I was, in the jury’s opinion, guilty of laundering £1.8Million pounds, acting art and part (in concert) with Caroline Laing, on the basis of the flimsiest of circumstantial evidence which it decided was sufficient to prove that I suspected that the money was dirty. Again, not that I knew or not that I should have suspected ….. but that I did actually suspect.

For such a verdict to be properly reached, the jury would have to have been able to understand firstly, the considerable detail of the case and secondly, the thinking processes of a solicitor in private practice in my situation.

When the judge came to sentencing, he reduced the value of my offence to around £1.3Million pounds on the basis that I had no knowledge of a sum of £500,000 which was handled by Caroline Laing alone through her personal bank account. I received a sentence of four years. He then sentenced her to two and a half years on the basis of her having handled the £500,000.

However, there was clear evidence throughout the trial that Caroline knew about the £1.3Million which I handled - she assisted in the property transactions and signed documents relative thereto as a power of attorney. She was convicted of the same charge as me so the judge should surely not have come to the conclusion that she should be sentenced on the handling of the £500,000 alone. Nevertheless, she still received a lesser sentence, presumably based to a large extent on that amount (I appreciate that my position as a solicitor was also taken into account). I only say this to highlight the complexities and inconsistencies of the case. I have never hoped that Caroline either be found guilty or receive a longer sentence.

And if the judge regarded it as appropriate to be specific at the time of sentencing about the offences of which we had been found guilty, should there not have been a direction on that distinction in his charge to the jury given the complexity of the case? I accept that the judge’s primary role in charging the jury is to direct on the law and he can often leave everything else to the jury with little or no comment. However, that was never going to happen in such a complex case and the judge rightly gave a lengthy charge, covering many areas of the trial evidence. Surely then, if the distinction between the offences was made at sentencing, it should have been important enough to merit direction in the charge.

The Crown had deliberately prosecuted Caroline and I under the one set of charges, the contention being that, all along, we had been working together to protect and hide Voudouri when the truth was that our roles had been significantly different. I had never met or even communicated with her in any way until some ten months after I started acting for Voudouri and most of the transactions I handled were completed during that period of ten months.

Also, Solicitors naturally handle substantial sums for their clients while accountants do not and, on top of the handling of the £500,000, evidence had been led that Caroline continued to help run Voudouri’s companies for some time after his conviction, that she had lent money to him and that she had paid off his credit cards, matters which clearly went against her. I knew nothing about any of these dealings and again surely if the distinction was significant enough to be made at sentencing, it was only right that it was emphasised to the jury during the charge.

It therefore follows that, from what the judge said at sentencing, the jury must have at the very least, wrongly found me guilty in respect of the £500,000 and, given this and other points above, the application of the principle of art and part to this case should surely be a matter for proper consideration at appeal.

The jury’s decision was reached despite the fact that in court it was proved that, with very minor exceptions which can always be uncovered during an audit, I followed all the Law Society’s professional guidelines on procedure and that the money was ‘cleaned’ as per the normal money laundering interpretation, long before it got to me. I acted at a time when the real requirement was to ‘know your client’ and it was confirmed in court that everyone who was involved in the Voudouri companies and with whom I had any dealings, was whom they declared themselves to be.

The training by the Law Society at that time had also always been focused on the recognising of when money was being ‘laundered’- not recognising when POC which had long since been cleaned or had never been dirty in the first place, was being handled. And the targets of any potential money laundering had always been drugs dealers or gun runners. VAT fraud had never been on the radar.

The case should be viewed against a background of statistics produced by the Law Society in their hand-outs on money laundering in 2003, after the POC Act had come into force. These disclosed that, at that time, well over 90% of solicitors in Britain had never made a report under the POC Act or the earlier money laundering laws and something approaching 60% were strongly against the idea of ever making a report. The mind-set of the profession at large must surely be of relevance when considering my mind-set at the time.

The Crown and HMRC

In December 2012, some six weeks into the trial, the Crown prosecutor asked for a day off (an unusual step I am told) to discuss the case with those who were instructing him, presumably the Solicitor General and HMRC. I understand that he was concerned at the standard of evidence which had been led up to that point. This followed a few days of evidence from a number of prosecution witnesses, all solicitors, some of whom had acted for the Voudouri companies and others who had acted on the other side of transactions from me. The evidence from those witnesses was very favourable to me and helped show that I had followed the money laundering rules which were in place at the time of the transactions. The witnesses also confirmed that the law had changed significantly since the period during which I acted and that, at the time of the trial, it was continuing to evolve.

I understand that, following a meeting the next day with those instructing him, the prosecutor was told to get back into court and get on with it. I am convinced that, from that point on, his attitude noticeably changed. For instance, he would make a point of saying “I am told that my next witness is...” I suggest being flippant or certainly displaying a lack of commitment. I was also told by one of my agents that the prosecutor openly admitted to him after the meeting that he was angry at having to continue with the prosecution when the guilty parties had been let off.

Also, before reaching its decision, the jury came back in and asked a question about whether a certain sum of money detailed in the indictment, related to the purchase of a specific property. This transaction was one of the most prominent in the case. It had been mentioned on day one and then referred to regularly over the three months. It was one of the most basic points to be understood in the trial but there was obviously still confusion amongst the jurors at that advanced stage. Everyone in the court, including the judge and the Crown, were clearly surprised at them having to ask the question. If they could not get this, how could they then have managed to understand any of the much more complex matters?

Prejudice and Doubt

On the day before the decision, the Sunday Mail ran the latest in a series of articles on about Voudouri, detailing how he had been traced to Cyprus and publishing pictures of him enjoying a lavish lifestyle there. The jury had sat there for three months listening to how these crimes, involving huge amounts of money, were perpetrated by many people who had got away with them and the report could only have helped influence the members’ decision against us as the two accused left in court.

Looking back, they were unlikely to have any sympathy with a solicitor who was comfortably off and was dealing with money which came through major banks, unpopular institutions with the public at the time. The trial had started with evidence being led on a tax charge which I will go on to explain below, so the jury were aware of my personal financial position, including income and assets.

Even if they were not prejudiced against me or the banks, they were asked to understand the extremely complex detail of the case and the average solicitor would have had trouble taking it all in, never mind the average layperson. I also do not think that I should have had to rely on the existence of reasonable doubt, there just being just no evidence of my suspecting. Either way, I question how the jury could decide that there was no reasonable doubt. There was considerable doubt on every point which the prosecution attempted to make against me.

“Get Him”

Looking back, it is clear that the court had the benefit of hindsight over me, in respect of what Voudouri and his partners had done and my position was not helped by the regular reports about him in the press. I am obviously critical of the jury’s decision but equally critical of HMRC and the Crown. As one of my legal team said- “the job of the prosecution is to get the case as far as the jury” and that is what they did. They took advantage of its complexity and the natural lack of understanding of a jury of the important legal issues, a jury which would have been likely to start from the point of view of there being ‘no smoke without fire’. Because the law is based on suspicion, there was never any possibility of the judge ruling that there was no case to answer.

The indictment was also framed at the start of the trial on the basis that I was involved in the laundering of £38Million. It was then amended on the first day to reduce the amount of the charge by (a mere) £35Million to £3Million. By the time it came to sentencing this was down to £1.3Million, consisting of four relatively small transactions. So again, up until the first day, HMRC were obviously still basing their case on the fact that I was part of the ‘gang’, even although there was no evidence of it. This allegation was then something which was disproved as the trial progressed but, with the charge being based on suspicion, it was possible for the Crown to continue to the end and they got their result by getting it as far as the jury.

There were number of points during the trial where the approach of the authorities was highlighted. One in particular will maybe give the appropriate flavour.

A former employee, who had left our firm some years before the investigation, was giving evidence as a prosecution witness and what she was saying in the witness box did not reflect what was in the signed statement which had been lodged as part of the disclosure. The judge was concerned about this so he sent the witness home and ordered that the tape of her interview with HMRC be located and played in court. When this was done it was clear that the signed statement did not match what had been said by her during the interview and she had obviously just signed what had been put in front of her when HMRC went back to see her the second time.

The statement said that my firm “paid lip service to the money laundering rules” when this had never been said at the interview. The judge was clearly unhappy and stated he did not expect any other similar discrepancies to arise, the suggestion being that there would be consequences if they did. None did but we will never know what else was in the disclosure (there were many statements which did not reflect the truth, made by people who were never called as witnesses) which put pressure on the Crown to prosecute when it was not a true reflection of what had been said. This particular witness statement was also at the very beginning of the disclosure and would have undoubtedly given some early momentum to the prosecution.

Many solicitor friends have reminded me of the time when the Crown was run by people who were first and foremost interested in justice being served. I am told that, today, the system is driven by the desire to land convictions and they would pull no punches in their pursuit of ‘getting’ a solicitor for the first time under the POC Act, even if that solicitor was in his fifties, was someone who had never done anything illegal in his life and had no motive or gain. I suggest that the Crown should have been big enough to bite the bullet and, in the absence of proper evidence against me, drop the case, even at an advanced stage. The prosecutor obviously thought that this should happen.

My background was that I had never been in trouble with the Law Society or any other authority during my twenty-five years in practice and I both had, and still have, a perfect credit record. My firm’s accounts were audited regularly and often the Law Society specifically commented that the standard of record keeping was good. I was comfortably off with a healthy family and healthy businesses. I have yet to be given a good reason why I would deliberately act for a client in circumstances where I suspected that he was laundering money. There would be no motive for or benefit from such a decision and a considerable downside to taking it.

Restriction and Confiscation

A restriction order was served on me in February 2006. Such an order has the effect of the Crown having control over all the financial affairs of the restricted party, usually until the outcome of a case is known. Despite there being no evidence of it, the application for the order narrated that there was good reason to believe that I had both been actively involved in and benefitted from, money laundering. It also made the quite ridiculous assertion that I was "living beyond my means", a common wording used in such applications against those who have acquired substantial assets despite them never having had a legitimate income. This was just another underhand ploy by HMRC to create excitement. At that point no one had made any attempt to examine my financial situation and, very quickly thereafter, I was able to provide a clear and detailed breakdown of it, showing how all my assets had been acquired legitimately. Nevertheless, the Crown refused to lift the restriction.

I was eventually served with a petition (the document initiating criminal charges) in October 2009. This made no mention of any offence which suggested that I was the holder of POC. Accordingly, I proceeded with an action for removal of the restriction and a court hearing was set for consideration of the matter in March 2010. At that hearing the Crown confirmed to the judge that they had indeed nowhere made any specific reference to me having POC to date but they requested that the court “bear with them” as they would “uncover substantial POC” in my name before the indictment was due to be served (that had to be done by August 2010). The Crown’s promise was therefore that, at that point, they were still pursuing an active line of enquiry which would lead to the uncovering of substantial sums which I had gained from the deliberate laundering of money and this would be reflected in the charges in the indictment.

Accordingly, I think we can presume that on the basis that the Crown would be serving an indictment on me within five months of that point, accusing me of not only laundering dirty money but also pocketing it, the judge ruled that the restriction should remain in place.

In August 2010, the indictment was duly served but it contained no charge in respect of me having the substantial proceeds of crime referred to in the March hearing. Accordingly, it must be presumed that there never was a hot line of enquiry and that those instructing Crown counsel deliberately misled the court during that hearing. (Again, with hindsight, we should have at that hearing, asked the judge to force the Crown to disclose to him in confidence, the detail of that hot line of enquiry).

All of this ties in with what I have said earlier about HMRC/the Crown’s attitude in pursuing me and the accusation against me changing as time passed, from one of me being part of the gang to one of me being suspicious. HMRC obviously had the restriction order served on me then went on a ‘fishing expedition’ to find POC in my name. They did this despite the fact that a potential abuse of the law of this nature was one of the major concerns of Parliament in the run up to the POC Act coming into force.

At the time of this hearing of March 2010, the Crown acknowledged that there was an English decision on ML (called ‘Allpress’ - where a solicitor, who had been found guilty of handling POC, had had a confiscation order imposed on him personally for the amount of POC involved) but they would not necessarily be asking for this case to be applied to my circumstances, so confident were they of finding a 'pot of gold' in my name from an ongoing enquiry/hot lead as mentioned above. However, following my conviction, at a POC hearing in 2017, the prosecution then moved for the importing of the Allpress decision into Scots law and the court decided in its favour.

Accordingly, I was held personally responsible for the £1.3Million detailed earlier even although none of it had actually been in my personal possession and I had not benefited from it in the normal sense of the word. Furthermore, the circumstances of Allpress were substantially different from my case but the court was just not interested in the distinctions.

As a result, press reports have suggested that I pocketed large sums of laundered money when I did not pocket one penny.

In 2017, using the Allpress decision, the Crown confiscated £97,000 of my funds which were readily available. Following that, on their application, a discharge of the restriction against me was granted by the court. That discharge would not have been granted if they thought that I ever had had large amounts of POC.

During the court proceedings for confiscation, obviously in an attempt to bully me into settling and avoiding a hearing, the Crown also threatened to confiscate property which was clearly owned by my wife but I resisted and the court eventually ruled against them on this point.

So, despite never having taken a penny of laundered money, I paid £97,000 from funds which were legitimately mine.

Contrast that with the treatment of one of the directors of QTech. In court it was clarified that the Crown, under a "deal" with him, had confiscated £15,000 of his money which had been frozen earlier in the investigation against him, in return for a full discharge. The Crown allowed him, as explained to the court by the former head of the section dealing with Proceeds of Crime, "to keep the properties he owned as they had been in his ownership since before the time of any offence."

So, let’s break that one down. The Crown accepted £15,000 as they had already had control over it at the time that they decided not to prosecute him. OK. £15,000 in respect of what? The stealing of over £38Million in VAT? The money laundering of over £38Million of stolen VAT?

The confiscation must have been for some kind of offence but he was never charged and if he was allowed to keep his properties as he owned them before the time of any offence, firstly that again suggests that there was an offence and secondly it suggests that the amount involved in the offence was more than £15,000.

In my case the Crown took money which had always been mine and they tried to attach my wife’s property which was not only owned by her from before the time of my ‘offence’, it was just that … owned by her, not me.

The Tax Charge

During the course of the investigation HMRC discovered that I had been employing my wife at my firm for a period of thirteen years. My chartered accountant was both well aware of and comfortable with this. Up until the time of her appearing as a witness at the trial, she had also been a good friend and, as such, aware of my personal circumstances.

Another of the charges against me at the trial was that the employment of my wife was no more than a fraudulent scheme to reduce my tax liability. The charge narrated that she had done no work whatsoever over the period of thirteen years and I had therefore saved and, in turn, defrauded HMRC of approximately £3,000 per annum, totalling £39,000. The charge was not that I had overpaid my wife relative to what she did, just that she did not do any work, that is, she did not lift a finger.

My wife had actually done a reasonable amount of work for me over that time, some of the tasks important to me, some menial, ranging from giving me advice on financial, mortgage and staff matters (she was formerly an assistant manager and mortgage advisor at Abbey National Building Society) to organising hospitality and much more. It is impossible to not have your wife help you in some way or another over thirteen years when you are the senior partner in a legal firm with forty plus employees and it is common practice throughout the legal profession and other professions and industries to employ spouses. Indeed, there were other partners in the firm who employed their wives/partners, both during my time as a partner and after I left. None has been prosecuted.

In addition, it was confirmed in evidence by HMRC and accepted by the Crown, that I could have easily organised my affairs in a different way and legitimately saved more than £3,000 per annum in tax but they argued that, because I chose not to do that and paid my wife, I was guilty of an offence.

In the event, after hearing the testimonies of (a) a bitter former colleague who said that the employment of partners’ wives (including his) was purely a device to avoid tax and that my wife did nothing at all to assist me at any time and (b) my former accountant, who ran scared of HMRC and lied in court about her relationship with me and her knowledge of my personal circumstances, the jury decided that the payment of my wife was purely a device to defraud HMRC and that my wife had indeed not once lifted a finger to help me over the period of thirteen years. So, I was convicted of that charge too.

This was no more than an underhand tactic by HMRC to get at me in any possible way and make it look as though I was some sort of habitual offender.

The Spin

There was a ban on press reporting during the trial at the request of the Crown who said, at the first hearing of the case in 2009, that they did not want to prejudice their position (through publicity) in respect of any potential future prosecution of one of Voudouri’s associates who was abroad. However, from later statements made at the trial, it was clear that an early decision had been taken to abandon such a prosecution.

So, there were no reporters in the court until the day of the verdict.

The day after the verdict and on the subsequent Sunday, it was reported that I had been found guilty of being a “bent lawyer, a trusted lieutenant of Voudouri who had hid him from the authorities” in an effort to launder his money.

Where then did the press get this description? They were not in court to hear the detail of the trial which, in any case, would have confirmed that Voudouri was clearly mentioned on my firm’s files and records for all to see. I had discussed him openly with my colleagues and passed his files to others for action. The press had no knowledge of me being ‘a trusted lieutenant’.

Either then HMRC or the Crown fed these quotes to the press, again to cause excitement.

Obviously I consider the verdict to be wrong in the respect that the jury decided that I ‘did suspect‘ but even then that is a long way from me being deliberately portrayed as an active criminal who was loyal to Voudouri. I got on well with him and carried through the legal work to the best of my ability but I neither hid him nor was close to him and no-one who had listened to the evidence would have suggested otherwise. So yet again the truth was twisted.

It was very difficult for me to listen to the judge’s comments when passing sentence, comments which were also reported in the press and which would obviously influence how the case looked ‘from the outside’. It should, however, be remembered that those comments were based on the jury’s interpretation of the facts. The judge also said that I was convicted of “being concerned in an arrangement which I knew or suspected facilitated the retention or use of criminal property; in other words, being knowingly concerned in the facilitation of money laundering” which is, at the very least, confusing. I repeat yet again - there was no evidence of my knowing - the jury decided that I had been suspicious.

The Appeal

I appealed against the conviction under some six main grounds of appeal, all of them considered to be valid by my counsel.

At the same time as my appeal was lodged, I made an application for interim liberation. A High Court judge looked at that application and granted my immediate release before the first sift (the first stage of the application for leave to appeal), based on what he saw as the grounds of appeal. So presumably he thought there was an arguable case - the Court of Appeal should allow an appeal where there is an arguable case (or ‘stateable case’ as it is known). My advisors, not ones to tell you what you want to hear just to keep you happy, told me that there was clearly a stateable case.

The appeal was then refused at both the first and second sifts (normally, I am told, the consideration of the request for leave to appeal by firstly one appeal court judge, then two or three appeal court judges). The trial judge has the opportunity to comment on the application for leave to appeal at the first sift stage in what is known as the ‘judge’s report’. My advisors are of the opinion that, in my case, the trial judge’s report did not answer the points of the appeal.

Between the first and second sifts my senior and junior counsel submitted a detailed and well-reasoned joint opinion, explaining why they thought that both the trial judge and the appeal court judge at the first sift, had not addressed the points being made. Nevertheless, the appeal court judges at the second sift accepted what the trial judge had said without qualification or explanation and leave to appeal was again refused. In effect they ‘put a pen through’ the application with no answer even being offered to the points made in the opinion.

As a result, I went back to prison.

After the refusal of the appeal, I applied to the Scottish Criminal Case Review Commission for a review of my case. That body has the ability to force the Appeal Court to hear a full appeal. However, after three applications, the Commission refused to order a referral back to the Appeal Court. Three applications were required as, despite detailed and well-reasoned appeal points being raised with them by my Counsel, proper responses were, yet again, never given. Indeed, in reply to the first application, the Commission never even bothered to answer all the points raised and it based any answers it gave solely on the judge’s charge to the jury (it did not look at one other scrap of evidence) when parts of my appeal were clearly against the contents of that charge. So, once again a ‘broad brush’ response was received.

Do the powers that be think that it is simpler to leave me where I am, the conviction of a solicitor for money laundering for the first time in Scotland and the application of the Allpress case being desirable outcomes?

The jury’s decision re the facts, of course, remains unchallengeable. This is despite there being increasing concerns regarding juries sitting in complicated cases. Statistics suggest that two thirds of jurors do not properly understand most cases never mind very complicated ones and the average attention span of a juror is very short. Some of them were sleeping at points during my trail. I suggest that, in a fair system, my case should never have been allowed to reach a jury.

I also suggest that the case was of such importance to the legal profession and indeed to any future prosecution under the POC Act, that the appeal points should have been properly addressed in the Court of Appeal.

Summary

So Voudouri’s wife, his father in law and his main associates were all freed with no possibility of any of them being brought to justice. In addition, there are friends and relatives of Voudouri who were actively involved in his schemes and who will never be prosecuted. Voudouri was eventually sentenced to eleven and a half years imprisonment for money laundering and absconding.

Then there is a minimum of ten other parties, from financiers to couriers, many of whom were mentioned in the trial and indeed some of whom were called by the prosecution as witnesses against me, who were shown to have active roles in the QTech fraud (ten is probably the tip of the iceberg). Again, all of these people will remain free despite the fact that they helped defraud HMRC of what is most likely to have amounted to hundreds of millions of pounds, money which HMRC handed to them on a plate.

Meantime, other than Voudouri, Caroline Laing and I are the only ones who have been convicted of anything to do with the QTech fraud when it was accepted that I had not even heard the name QTech until some five years after my ‘crime’ and I had handled an extremely small proportion of the QTech money.

For my part, I can say without fear of contradiction in any reasonable argument, that I only did what I thought was expected of me as a solicitor.

As mentioned at the start, there is much more to this but that is for another time.

For the moment, maybe the foregoing will help explain why I am neither a criminal nor have been reckless, foolish or even naive.

RH.