Disciplinary outcome: Douglas Cully

Douglas Cully’s professional or personal conduct, was found to be in breach of the Code of Professional Ethics and to have posed a risk to the public or was likely to undermine public confidence in the Association or its members; namely:

1. He failed to comply with his obligations under the Money Laundering Regulation in force while providing accountancy and/or bookkeeping services to the public, specifically:
   1. between on or around 26 June 2017 and on or around 23 March 2021, he did not maintain an adequate written record of his anti-money laundering policies, controls and procedures: and/or
   2. between on or around 26 June 2017 and on or around 23 March 2021, he failed to apply adequate risk-based due diligence and ongoing monitoring measures in respect of one or
   3. between on or around 01 October 2014 and on or around 23 March 2021, he did not carry out and/or record an adequate firm-wide money laundering risk assessment: and/or
   4. between on or around 01 October 2014 and on or around 23 March 2021, he did not carry out an adequate review of his anti-money laundering policies, controls and procedures.
2. For an unknown period up until on or around 23 March 2021, he failed to issue a disengagement letter to one or more clients as required under paragraph 10 of AAT’s Client Care policy.
3. For an unknown period until on or around 23 March 2021, he failed to issue an adequate letter of engagement to one or more clients as required under paragraph 5 of AAT’s Client Care policy.
4. For an unknown period up until on or around 23 March 2021, he did not have adequate anti-money laundering training in place for your relevant employees in accordance with MLR 2017.
5. For an unknown period up until on or around 23 March 2021, he failed to maintain a continuity of practice agreement in accordance with AAT’s Continuity of Practice policy.

Grounds for disciplinary action existed and the matter was suitable for exercise of the Investigations team's powers under the Disciplinary Regulations.

Douglas Cully is hereby:

1. Divested of his fellow membership (FMAAT) status for a period of two years.
2. Fined: Fine totalling £2500
3. Warned that failure to pay the fine within the allotted period within 90 days or on such terms that Professional Standards believes is reasonable, will result in the immediate removal of his license and membership until such time that the fine is paid in full.
4. Severe reprimand: To remain live on Mr Cully’s record for a period of two years.

Consent