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Dunn & Baker LLP Faces SRA scrutiny over client identification lapses

Dunn & Baker LLP Faces SRA scrutiny over client identification lapses


Peter Gaywood rebuked, fined £300 for client identification failures by Solicitors Regulation Authority

At the heart of recent disciplinary action by the Solicitors Regulation Authority (SRA) is Dunn & Baker LLP, located at 21 Southernhay East, Exeter, EX1 1QQ, England, with Firm ID 605696.

In an agreed outcome, Mr. Peter Gaywood, an employee of Dunn & Baker LLP, faces the following consequences for an SRA-reviewed conduct:

  1. Rebuke.
  2. Publication of the agreement.
  3. Payment of £300 to cover investigation costs

Mr. Peter Gaywood, serving as a Chartered Legal Executive at Dunn & Baker LLP since May 26, 2021, found himself under scrutiny when a client identification lapse came to light.

In April 2022, handling the case of Client A, Mr. Gaywood omitted crucial client identification checks assuming prior completions. The oversight became apparent in June 2023 when another law firm requested details regarding a property transfer.

Upon investigation, it was revealed that Client A was a family member representing Person B, the actual property owner, exposing the failure in identification checks.

Mr. Gaywood acknowledges two critical admissions accepted by the SRA:

  1. Failure to conduct client identification checks for Client A.
  2. Breach of Principle 7 by failing to act in the best interests of each client.

In determining an appropriate outcome, the SRA considered several factors:

  1. Mitigating Factors:

    • Mr. Gaywood faced personal difficulties during the conduct.
    • No prior regulatory issues.
    • Full cooperation with the investigation.
    • Remedial actions taken, including self-reporting to CILEX and additional anti-money laundering training.
  2. Risk Assessment:

    • Low risk of repetition.
    • Although deemed reckless, Mr. Gaywood's conduct caused no significant harm to clients.
  3. Public Sanction:

    • Essential for upholding public confidence in legal services.
    • Emphasis on the potential harm, even if not realized.


The SRA deems it necessary for transparency in the regulatory and disciplinary process to publish the details of this agreement.

Mr. Gaywood commits to not denying admissions or acting inconsistently. Any violation may result in further SRA scrutiny, potentially leading to disciplinary actions.

Mr. Gaywood has agreed to pay £300 for the SRA's investigation costs within 28 days of receiving the statement of costs.