Disciplinary outcome: Andrew Wainwright

1. He failed to apply adequate risk-based due diligence and ongoing monitoring measures in respect of one or more clients, in accordance with Regulation 28 of the Money Laundering Regulations 2017.
2. He failed to carry out any or any adequate periodic review of his Anti-Money Laundering policies, procedures, and controls. In accordance with Regulation 21c of the Money Laundering Regulations 2017.
3. He failed to carry out any or any adequate annual compliance review, in accordance with regulation 33b of AAT’s Clients’ Money policy.
4. He failed to have a Continuity of Practice agreement in place, in accordance with AAT’s Continuity of Practice policy.
5. He failed to have adequate Professional Indemnity Insurance in place, in accordance with of AAT’s Professional Indemnity policy.

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

The Investigation Team orders that Andrew Wainwright be:

1. Fined £4,000
2. FMAAT status removed for two years
3. Severely Reprimanded for two years