Disciplinary outcome: Eamon Smart

Order by consent

In the matter of

Mr Eamon Smart MAAT

Membership number

3018

Date

28 November 2023

Misconduct

It is alleged that Eamon Smart, being a full member of the Association of Accounting Technicians ("AAT"), is guilty of misconduct in that: 

  1. He failed to comply with his obligations under the relevant Money Laundering Regulations while providing accountancy services to the public, specifically:
    1. From an unknown date until on or around 14 October 2022, he failed to have in place adequate and/or documented Anti-Money Laundering policies, controls and procedures.
    2. From an unknown date until on or around 14 October 2022, he failed to carry out any or any adequate client due diligence in respect of one or more clients.
    3. From an unknown date until on or around 14 October 2022, he failed to carry out an adequate risk assessment and ongoing monitoring in respect of one or more clients.
    4. From an unknown date until on or around 14 October 2022, he failed to carry out an adequate firm-wide money laundering risk assessment.
    5. From an unknown date until on or around 14 October 2022, he failed to carry out any or any adequate periodic review of his Anti-Money Laundering policies, procedures, and controls.
  2. Between an unknown date and on or around 14 October 2022, he provided limited assurance engagement services to the public without being licensed by AAT to do so.

Finding

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

Order

  1. Fined: £2,500.00
  2. Severe Reprimand, to remain live on Mr Smart’s record for a period of two years (24 months)

Consent

Eamon Smart has agreed to submit to the decision of the Investigations Team in accordance with Regulation 6 of the Disciplinary Regulations.