offered the Applicant significant sums of money which he said would be payable in cash at such location or in such manner as he chose. The highest and final offer made to the Applicant was in the sum of US$250,000, which the Applicant rejected. 54. The City of London Police commenced an investigation into C Limited early in 1985 which resulted in the Chief and certain former directors being arrested and some charged with fraud. The actions taken by the Applicant prior to the involvement of the police formed a significant part of the prosecution evidence and he appeared as a prosecution witness at Wallington Crown Court. 55. Whilst engaged in the affairs ofC Limited the Applicant was called as a prosecution witness at a trial held at the Old Bailey in relation to a group of Italians who had sought, fraudulently, to purchase C Limited's office premises in London. The Applicant appeared in the witness box for three and a half days, the majority of which time was spent seeking to rebut allegations put to him by two defence Counsel that owing to the fact that he was a struck off solicitor, he was either a co-conspirator with the accused or that he was a liar and that his evidence could not be relied upon. The jury accepted the Applicant's evidence; the accused were convicted. 56. Following the termination of his employment and until the C Limited trial, the Applicant was again without regular employment and could only manage to get by as a result of undertaking various consultancy retainers on behalf of a number of companies and individuals with whom he had become acquainted during his employment with C Limited. Possibly because of his employment with C Limited, no-one was prepared to offer full time employment to him. 57. The Applicant had come to form the view that he had been employed by C Limited because there was an expectation or a hope that would be able to assist in veneering frauds because of his perceived dishonesty. He believed that this was why he had been talked out of pursuing his appeal against the Tribunal's Order. 58. For the ten year period which began with the conclusion of C Ltd's criminal trial until August 1997 when the Applicant commenced his current employment he worked variously for firms of solicitors (with the consent of The Law Society) and for commercial companies. (See: Solicitors Lie Detector. The Law Society gave no such consent. UJ) 59. Although the Applicant enjoyed periods of employment with those firms of solicitors who had agreed to employ him, he always felt that his employment was never destined to be long term owing to what he saw as enormous reservations in relation to, not only the manner in which he was represented to clients of those practices, but also those areas of work he was allowed to undertake. He fully understood why a firm of solicitors should hold those reservations but having always wanted to be a solicitor and to practise law, the Applicant for many years felt frustrated, believing that he would never be given the opportunity to demonstrate or realise his full potential for the benefit of those practices, their clients or indeed himself. His employment with each of those practices was terminated by mutual consent. 60. In 1991 the Applicant accepted a retainer to work on a part time basis with an American oil company. He was required to visit Siberia and Kazakhstan on occasions. He studied the Russian language. 61. During the early part of 1990 the Applicant had met and became friendly with Mr S, the Managing Director of the London office ofOCRA. 62. OCRA was established some 27 years ago initially as an international company formation agent but had developed into an international corporate service provider with a significant international tax and corporate practice. In the majority of cases, OCRA's offices were staffed, managed and controlled at a senior level by lawyers and accountants qualified in the jurisdiction of establishment. It generated a substantial income. 63. Between 1990 and 1997 the Applicant became increasingly familiar and friendly with the main Board of Directors of OCRA both in London and elsewhere and by the time his retainer with the American oil company had ended in late 1996 he was spending an increasing part of his working week assisting OCRA. (What, then, was Daultrey doing at the offices of Donnellan & Co,
from where he pretended to be a solicitor of 20 years' standing? UJ.) 64. In 1997 the Applicant was asked to commit to OCRA three days each week in order to oversee the continuing development of its professional and compliance divisions. At that time the Applicant was in the final stages of registering to become a part time student and to study for a PhD. (At OCRA Daultrey continued to pretend to be solicitor of 20 years' standing) 65. The Applicant commenced part-time employment on a formal basis with OCRA in August 1997 and within a matter of months found that he was working five days each week on OCRA's business and spending little or no time on his intended PhD. After 12 months he was offered the opportunity to work full time with OCRA which he agreed to do. He has remained there rising to Group Director. 66. At the time of the hearing the Applicant was one of five executive directors sitting on the boards of the two holding companies. Estate and General (IOM) Limited and Estate and General (International) Limited which control OCRA's business throughout the world. In that capacity he was charged with particular responsibility for compliance and was the Group MLRO. He was a signatory on a number of OCRA's bank accounts. OCRA has client account rules and is subject to review and scrutiny by Government Regulators. 67. The Board of Directors of OCRA had at all times been fully aware of the Applicant's professional position. It had during the previous 23 years been the Applicant's invariable practice, however difficult or embarrassing to tell third parties of those events which took place in 1980 and 1982 and to explain his position to those with whom he had professional or business dealings. It was also known by OCRA that the Applicant had "blown the whistle" while at C Limited. 68. By the very nature of OCRA's and other international advisory and consultancy businesses there will always be a risk of exposure to criminal activity by others and in particular to money laundering and tax evasion and having a worldwide client portfolio numbering in excess of 10,000 the task of regulating that business is significant. Those tasks fall within the remit of a Compliance Officer and MLRO. The Applicant had faced significant pressure in that role. His bona fides had from time to time been challenged on the basis that he was a struck off solicitor in an attempt he assumed to coerce him to change his mind. On no occasion had he succumbed. 69. The Applicant had developed a relationship with a number of police forces around the country in particular with the Metropolitan Police, the National Criminal Intelligence Service ("NCIS") and the National Crime Squad ("NCS"), HM Customs & Excise and the Inland Revenue and also with other Government law enforcement agencies. 70. Within a short time of his commencing employment with OCRA, the Applicant had formed the view that it would be necessary in the light of the increasing regulatory legislation being enacted, for example, the Criminal Justice Acts, Anti Money Laundering and the Proceeds of Crime Act for OCRA to develop further its relationship with "the authorities". 71. The Applicant had approached the Metropolitan Police Fraud Squad and introduced OCRA and its business. He was invited to make an informal presentation to a division of the Fraud Squad describing the international aspects of OCRA's business, accompanied by a general summary of the rules of international trading and taxation. In November 1998 he was invited to be a guest speaker at the Metropolitan Police Feedback Forum which is an annual conference organised by the police and held at Scotland Yard. On the first occasion at which the Applicant spoke the conference was attended by 126 compliance/MLRO's from almost all the major international banks based in central London. Since that time the Applicant had been invited to speak variously at a number of police and other regulatory authorities conferences and also to run training courses for many divisions of those authorities. In February 2001 he was a guest speaker at the Annual NCIS Conference held at the Belfry. 72. Over the past few years the Applicant had variously been called upon to give opinions and to advise in respect of a number of intended or current police prosecutions where international issues arose and to train in some cases on a one to one basis, police officers from certain specialist divisions. He regularly received telephone calls and requests for assistance or advice from police forces around the country many of whom he had not met personally but to whom his name had been introduced by other officers who had become acquainted with the Applicant. 73. One of the more difficult aspects of the Applicant's role as Compliance Officer and MLRO arose when he was required, usually only for the purposes of presenting a file to court, to attend and give evidence before the Crown Court on behalf of the prosecution. Each time he entered court, for what he knew to be usually only a routine matter, he was concerned that as had sometimes been the case, his professional history would be raised in an endeavour to discredit the evidence he might give and that this would in some manner adversely affect the prosecution case. 74. For many years the Applicant had resigned himself to remaining as a businessman and his love and enjoyment of the law notwithstanding, he had put out of his mind the possibility of being restored to the Roll of Solicitors. He knew that applications for restoration were rarely granted. 75. The Applicant had always believed that he was an honest person both in his personal and professional dealings. He invited the Tribunal to conclude that his behaviour when he was immature and under stress during a few months in late 1980 was wholly out of character both before that brief period and during the subsequent 23 years. 76. It was only recently that the Applicant had come to realise that the possibility of his restoration to the Roll of Solicitors existed in the minds of a number of clients, professional and business contacts and valued friends who had expressed confidence in him, his character and professionalism and who questioned why he had never sought to be restored to the Roll. 77. It is for those reasons and based largely upon the encouragement he received, much of it from solicitors and barristers in private practice, that the Applicant began to consider whether or not his name might be restored to the Roll. He had been encouraged by his employers. More widely and with a view to his becoming an expert prosecution witness the Applicant had been asked by the police to consider seeking the restoration of his name to the Roll. Restoration would also enable him to assist the authorities more effectively. 78. The Applicant would also like to return to voluntary work at the CAB but he had no real value to the CAB except as a practising solicitor. He would wish to become more involved with charitable matters as an honorary solicitor and in particular with a breast cancer charity in which his wife was a significant participator. 79. The Applicant had been advised that restorations to the Roll are extremely rare and only occur when an Applicant can show that wholly exceptional circumstances applied at the time of the commission of an offence which gave rise to a striking off and where there was also convincing evidence that the Applicant had been fully rehabilitated and would be an asset to the solicitors' profession if restored to the Roll. 80. In presenting his application the Applicant wished to reiterate that he was not seeking to appeal against his striking off but he respectfully submitted that the circumstances of his application met both criteria. 81. The Tribunal was invited to give due weight to the written letters of support which included letters from senior members of the legal profession, bankers, police officers, a member of the House of Lords and a non-executive Chairman of OCRA, a chartered accountant, financial regulators and the Group Financial Director of OCRA, all of whom spoke highly of his integrity, trustworthiness or good character and confirmed his competence and ability in the field in which he works. 82. The nature of the position which the Applicant had in his employment and the trust which he enjoyed both from his employers and regulatory authorities in the UK and elsewhere, demonstrably showed that he had not re-offended during the past 22 years and was most unlikely to do so in the future. 83. The standing in which the Applicant was held in the minds of professionals with whom he worked and who were aware of his rehabilitation, demonstrated that those actions which he undertook during a short period in 1980 were wholly out of character.