Disciplinary outcome: Dawn Clarkson

1. She failed to demonstrate and/or record adequate money laundering risk assessments for two existing clients, in breach of Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
2. She failed to apply appropriate customer due diligence measures in respect of one client, in breach of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
3. She failed to update customer due diligence to reflect changes regarding one client operating within a specified high-risk country in breach of Regulation 33 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
4. She failed to receive and/or hold client monies in accordance with the requirements of AAT's Clients' Money policy.
5. She provided or held herself out as providing limited assurance engagement services without being licensed by AAT to do so, in breach of Regulation 6.4 of AAT’s Licensing Regulations.

By reason of the conduct set out in the Allegations above, Dawn Clarkson 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. Removed of fellow membership status for a period of three years.

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.