Disciplinary outcome: Edward Harman

1. For an unknown period until on or around 3 July 2025 he failed to conduct criminal record checks for two individuals considered to be a beneficial owner, officer or manager of the Firm, in breach of Regulation 26 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
2. For an unknown period until or around 3 July 2025 he failed to record and/or demonstrate adequate customer due diligence in respect of one or more clients in breach of Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
3. For an unknown period until on or around 3 July 2025, he failed to apply appropriate customer due diligence measures in respect of one or more clients, in breach of Regulation 35 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
4. For an unknown period until on or around 3 July 2025 he failed to retain records for the minimum specified time period for one or more clients, in breach of Regulation 40 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
5. For an unknown period until on or around 3 July 2025 he failed to receive and/or hold client monies in accordance with the requirements of AAT's Clients' Money Policy.
6. For an unknown period, he has been providing or holding himself 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, Edward Harman 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 £8,500.00.

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.