Disciplinary outcome: Arshiya Shaheen

1. She did not comply with her obligations under the Money Laundering Regulations in force while providing accounting services on a self-employed basis. Specifically, she failed:
   • conduct regular compliance reviews of her firm’s anti-money laundering policies, controls, and procedures; and/or
   • carry out and/or document any or any adequate client due diligence (CDD) for one or more new clients; and/or
   • carry out and/or document any or any adequate ongoing CDD for one or more existing clients.
2. She failed to ensure clients’ money was held in a separate bank account designated solely for client funds.
3. She failed to have a continuity of practice arrangement in place as required under AAT’s Continuity of Practice Policy.
4. She failed to have professional indemnity insurance (PII) in place as required under paragraph 5 of AAT’s PII Policy.
5. She failed to issue a letter of engagement to one or more clients that fully complied with paragraph 5 AAT’s Client Care Policy.

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

1. Reprimanded for a period of four years
2. Fined £3,500
3. Deemed ineligible to hold fellow member (FMAAT) status for a period of four years
4. Warned about her future conduct.

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.