Disciplinary outcome: Carl McCabe

1. He failed to comply with his obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Specifically, he failed to comply with one or more of the following requirements:
   • adequately document the money laundering risk factors underpinning client risk assessment conclusions for one or more new and/or existing clients
   • ensure that anti-money laundering training was effective and/or adequately evidenced
   • adequately document ongoing customer due diligence for one or more existing clients.
2. He failed to hold clients’ money in accordance with paragraphs 9(b), 10, 15 and 33b of AAT’s Clients’ Money Policy.
3. He failed to maintain an adequate continuity of practice arrangement in accordance with AAT’s Continuity of Practice Policy.
4. He failed to issue and/or retain compliant engagement letters for one or more clients, contrary to AAT’s Client Care Policy.
5. He undertook a Limited Assurance Engagement while not approved by AAT to provide such services.

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

1. Severely reprimanded for a period of three years
2. Fined £5,000.00
3. 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.