Mahfuzur Rahman
Solicitor
594846

Decision - Agreement

Outcome: Regulatory settlement agreement

Outcome date: 21 September 2026

Published date: 23 September 2026

Firm details

Firm or organisation at time of matters giving rise to outcome

Name: Spencer West LLP

Address(es): Longbow House, 20 Chiswell Street, London, EC1Y 4TW

Firm ID: 555456

Outcome details

This outcome was reached by agreement.

Decision details

1. Agreed outcome

1.1 Mr Mahfuzur Rahman, a solicitor and former employee of Spencer West LLP (the firm), agrees to the following outcome to the investigation of his conduct by the Solicitors Regulation Authority (SRA):

1. he is fined £4,950 under Rule 3.1 (b) of the SRA Regulatory and Disciplinary Procedure Rules (RDPRs).
2. to the publication of this agreement under Rule 9.2 of the RDPRs.
3. he will pay the costs of the investigation of £1,350, under Rule 10.1 and schedule 1 of the RDPRs.

2. Summary of Facts

2.1 The SRA commissioned a Forensic Investigation into the firm. The Forensic Investigation Officer (FIO) reported in the Forensic Investigation Report (FIR) that Mr Rahman had allowed the firm's client account to be used as a banking facility by making payments which did not relate to an underlying legal transaction or to a service forming part of the firm's normal regulated activities.

2.2 Some of these transactions also involved Mr Rahman acting in circumstances where there was a significant risk of an own interest conflict by making payments to companies he himself controlled or that were controlled by family members.

2.3 The payments were made at the request of the client. There is no evidence of client loss, misapplication or funds, or of any complaint by a client or third party.

3. Allegations

3.1 Between September 2022 and May 2023, Mr Rahman allowed Spencer West LLP's client account to be used as a banking facility in four separate matters.

3.2 While acting in each of the transactions referred to above, and by making each of the related payments to companies owned by family members, as well as for the benefit of his own company, Mr Rahman acted in circumstances where there was a significant risk of an own interest conflict.

4. Admissions

4.1 Mr Rahman makes the following admissions which the SRA accepts:

1. That by allowing the firm's client account to be used as a banking facility he failed to act in a way that upholds public trust and confidence in the solicitors' profession and in legal services provided by authorised persons in breach of Principle 2 of the SRA Principles 2019.
2. That by allowing the firm's client account to be used as a banking facility he breached Rule 3.3 of the SRA Accounts Rules 2019 which states that you must not use a client account to provide banking facilities to clients or third parties. Payments into, and transfers or withdrawals from a client account must be in respect of the delivery by you of regulated services.
3. That by acting in each of the transactions and by making each of the related payments to companies connected to family members and for the benefit of a company in which he was a director, he acted in matters where there was an own interest conflict or a significant risk of such conflict in breach of Paragraph 6.1 of the of the Code of Conduct for Solicitors, RELs and RFLs.
4. That by acting in each of the transactions and by making each of the related payments to companies connected to family members and for the benefit of a company in which he was a director, he failed to act in a way that upholds public trust and confidence in the solicitors' profession and in legal services provided by authorised persons in breach of Principle 2 of the SRA Principles 2019.

5. Why a fine is an appropriate outcome

5.1 The SRA's Enforcement Strategy sets out its approach to the use of its enforcement powers where there has been a failure to meet its standards or requirements.

5.2 When considering the appropriate sanctions and controls in this matter, the SRA has taken into account the admissions made by Mr Rahman and the following mitigation which he has put forward:

1. There is a low risk of repetition.
2. Mr Rahman has no adverse regulatory history.
3. Mr Rahman has cooperated with the SRA Investigation.

5.3 The SRA considers that a fine is the appropriate outcome because:

1. Mr Rahman was an experienced solicitor who had direct responsibility for the matters.
2. Mr Rahman's conduct showed a disregard for his regulatory obligations to exercise proper management over client account money.
3. Mr Rahman's conduct in making these payments persisted longer than reasonable and was not rectified until prompted.

5.4 Rule 4.1 of the Regulatory and Disciplinary Procedure Rules states that a financial penalty may be appropriate to maintain professional standards and uphold public confidence in the solicitors' profession and in legal services provided by authorised persons. There is nothing within this Agreement which conflicts with Rule 4.1 of the Regulatory and Disciplinary Rules and on that basis, a financial penalty is appropriate.

6. Amount of the fine

6.1 The amount of the fine has been calculated in line with the SRA's published guidance on its approach to setting an appropriate financial penalty (the Guidance).

6.2 Having regard to the Guidance, the SRA and Mr Rahman agree that the nature of the misconduct was more serious (score of three). This is because his use of the client account as a banking facility in the four matters continued for eight months. The transactions of concern consisted of eighteen payments. Mr Rahman also acted in a number of transactions in which there was a risk of a conflict of interest. These actions demonstrate a pattern of misconduct.

6.3 The SRA considers, and Mr Rahman agrees, that the impact of the misconduct was low (score of two). This is because, while the monies involved in the matters was significant, the funds were all moved at the request of the client. Therefore, it is our view that the misconduct had the potential to cause minimal loss or have minimal impact.

6.4 The nature and impact scores add up to five. This places the penalty in band “B” as directed by the Guidance.

6.5 The SRA and Mr Rahman agree that a basic penalty at the top of the bracket to be appropriate.

6.6 Based on the evidence Mr Rahman has provided of his gross annual income for the relevant period, this results in a basic penalty of £4,950.

6.7 Mr Rahman does not appear to have made any financial gain or received any other benefit as a result of his conduct. Therefore, no adjustment is necessary, and the amount of the fine is £4,950.

7. Publication

7.1 Rule 9.2 of the SRA Regulatory and Disciplinary Procedure Rules states that any decision under Rule 3.1 or 3.2, including a Financial Penalty, shall be published unless the particular circumstances outweigh the public interest in publication.

7.2 The SRA considers it appropriate that this agreement is published as there are no circumstances that outweigh the public interest in publication, and it is in the interest of transparency in the regulatory and disciplinary process.

8. Acting in a way which is inconsistent with this agreement

8.1 Mr Rahman agrees that he will not deny the admissions made in this agreement or act in any way which is inconsistent with it.

8.2 If Mr Rahman denies the admissions, or acts in a way which is inconsistent with this agreement, the conduct which is subject to this agreement may be considered further by the SRA. That may result in a disciplinary outcome or a referral to the Solicitors Disciplinary Tribunal on the original facts and allegations.

8.3 Denying the admissions made or acting in a way which is inconsistent with this agreement may also constitute a separate breach of principles 2 and 5 of the Principles and paragraph 7.3 of the Code of Conduct for Solicitors, RELs and RFLs.

9. Costs

9.1 Mr Rahman agrees to pay the costs of the SRA's investigation in the sum of £1,350.