Disciplinary outcome: Benjamin Isaacs

1. He did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis. Specifically, he failed to:
   • apply to AAT for approval of two beneficial owner, officer, manager appointments; and/or
   • perform any or any adequate ongoing client due diligence for one or more existing clients.
2. He failed to hold clients’ money in a client bank account separate from the firm’s bank account as is required under AAT’s Clients’ Money Policy.  
3. He failed to maintain an adequate record of continuing professional development (CPD) activities undertaken as is required under AAT’s CPD Policy.
4. He failed to issue letters of engagement to one or more clients that were fully compliant with paragraph 5 AAT’s Client Care Policy.

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

Benjamin Isaacs is hereby:

1. Severely reprimanded for a period of three years
2. Fined £2,500
3. Deemed ineligible to hold fellow member (FMAAT) status for a period of three years
4. Warned about his 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.