Disciplinary outcome: Alireza Falamarz Fouladi

1. He failed to have in place and or any adequate Anti-Money Laundering training for himself and/or staff and/or
2. He failed to carry out any or any adequate risk assessment and ongoing monitoring in respect of one or more clients and/or
3. He failed to carry out any or any adequate documenting of client identification in respect of one or more clients and/or
4. He failed to carry out any or any adequate regular review of his Anti-Money Laundering policies, controls and procedures and/or
5. He failed to hold client’s money in accordance with AAT’s Clients’ Money Policy and/or
6. He failed to provide services in accordance with relevant accounting standards and statutory requirements.

By reason of the conduct set out in the Allegations above, Alireza Falamarz Fouladi is guilty of misconduct pursuant to Article 21 of AAT’s Articles of Association.

The Investigation Team orders that Alireza Falamarz Fouladi be:

1. Severely Reprimanded for a period of three years.
2. Fined £2,500.00

The decision of the Investigations Team shall stand as an Order of the Association pursuant to Regulations 5.2 and 5.3 of the Disciplinary Regulations