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Enforcement Determination Notices and Adjudication Panel Findings

Findings of the Adjudication Panel

Below are current findings. Unless otherwise directed by the Adjudication Panel, any disciplinary determination made against an individual or firm, will remain listed on the CLC website for the duration of any suspension, disqualification, or other sanction, subject to a minimum of 6 years from the date of publication in line with the CLC’s Publication Policy.

Enforcement Determination Notices

Enforcement Determination Notices (EDN) record enforcement decisions made by the Council for Licensed Conveyancers (CLC) in respect of licensed bodies (Alternative Business Structures) and/or and their regulated role holders, owners and employees, in relation to breaches to the CLC’s Codes they have committed. EDNs are not settled by the independent Adjudication Panel but are issued by the CLC following careful consideration of an entity or an individual’s representations in relation to misconduct. Publication of EDN is governed by the CLC’s Publication Policy.

Entity/Individual

Code Breaches

Date of Enforcement Notice & Penalty

Enforcement Notice

Silvia Ribeiro

Breaches of the Code of Conduct and the Accounts Code

7 March 2025

Disqualification from holding the post of Head of Finance and Administration (HoFA) or Registered Manager of any Licensed Body for 12 months.

Financial penalty: £3,375

Malcolm McLean

Breaches of the CLC's Code of Conduct, Accounts Code, AML and CTF Code

14 February 2024

Disqualification from employment and/or consultancy roles with any CLC licensed body. See also outcome of appeal to the Adjudication Panel

Nelson McLean Limited

Breaches of the CLC's Code of Conduct, Accounts Code, AML and CTF Code, Management and Supervision Arrangements Code

14 February 2024

Financial penalty: £8,775

James Keogh

Breaches of the:

Code of Conduct

Transaction Files Code

24th March 2022

Financial penalties totalling £5,000 Disqualification from holding any post or role in any CLC Licensed or Recognised Body.

James Keogh

Breaches of the:


Code of Conduct

Disclosure of Profits and Advantages Code

Conflicts of Interest Code

Complaints Code

Estimates and Terms of Engagement Code

Anti-Money Laundering and Combatting Terrorist Financing Code

Accounts Code

Management and Supervision Code

21st September 2021

Financial Penalty: £25,000

Disqualification from holding any post or role in any CLC Licensed Body.

Stratega Law Ltd

Breaches of the:


Code of Conduct

Conflicts of Interest Code

Complaints Code

Estimates and Terms of Engagement CodeAnti-Money Laundering and Combating Terrorist Financing Code

Accounts Code

Supervision and Management Code

31st August 2021


Financial Penalties: £204,943.90, made up of £106,012.50 + £98,931.40 (VAT exclusive), in respect of overcharging on files. 

Condition: The Licensed Body is prohibited from taking new instructions to act on both sides of transactions for a period of up to three years from 25 February 2021.

Germaine Spence

Breaches of the Code of Conduct

6th January 2023


Disqualification from employment in a CLC-regulated entity: 5 years


Financial Penalty: £3,300

HB Property Legal Ltd

(also trading as JP Goldman)

Breaches of the CLC’s Anti-Money Laundering and Combatting Terrorist Financing Code and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)

24th November 2021


Financial Penalty: £1,187.50

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