Disciplinary outcome: Cecilia Asamoah

1. She failed to have any documented anti-money laundering policies, controls and procedures in place.
2. She failed to regularly review anti-money laundering policies, controls and procedures in place.
3. She failed to carry out a firm-wide risk assessment.
4. She failed to have procedures in place for reporting discrepancies in the Person with Significant Control register.
5. She failed to have in place effective AML training for all staff.
6. She failed to effectively verify the identity of one or more clients.
7. She failed to perform a risk assessment for new and existing clients.
8. She failed to document ongoing client due diligence for existing clients.
9. She failed to obtain written approval from one or more clients regarding the filing of tax returns.
10. She failed to consider Independent Examination of charity accounts.
11. She failed to comply with AAT’s Clients’ Money Policy in that clients’ money totalling £132,484.00 was received into her firm’s office bank account.
12. She failed to have in place any or any adequate continuity of practice agreement.
13. She failed to have in place any and/or any adequate professional indemnity insurance cover.
14. She failed to issue a letter of engagement to one or more clients.
15. She failed to issue letters of engagement that were fully compliant with AAT’s Client Care Policy. 

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

1. Fined £8,400.00
2. Severely Reprimanded for a period of 5 years
3. Submitted to a practice assurance review, at her own cost 

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.