Disciplinary outcome: Diana Macfarlane
Order by consent
In the matter of
Mrs Diana Macfarlane MAAT
Business name
N/A
Membership number
15437
Date
09 February 2026
Misconduct
- For an unknown period, until on or around 09 January 2025, she failed to carry out an adequate firm-wide money laundering risk assessment in accordance with Regulation 18 of the Money Laundering Regulations 2017.
- For an unknown period, until on or around 09 January 2025, she failed to document or adequately document regular her Anti-Money Laundering policies, procedures, and controls in accordance with Regulation 19 of the Money Laundering Regulations 2017.
- For an unknown period, until on or around 09 January 2025, she failed to carry out any or any adequate regular review of her Anti-Money Laundering policies, procedures, and controls in accordance with Regulation 21 of the Money Laundering Regulations 2017.
- For an unknown period up, until on or around 09 January 2025, she failed to carry out an adequate risk assessment in respect of one or more clients in accordance with Regulation 28 of the Money Laundering Regulations 2017.
Finding
By reason of the conduct set out in the Allegations above, Diana Macfarlane is guilty of misconduct pursuant to Article 21 of AAT’s Articles of Association.
Order
The Investigation Team orders that Diana Macfarlane be:
- Fined £1,500
- Severely Reprimanded for 2 years
Consent
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.
