Disciplinary outcome: Elliot Massey

1. He did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis. Specifically, he failed to:
   • conduct a regular compliance review of his firm’s anti-money laundering policies, controls, and procedures; and/or
   • adequately document client due client (CDD) for new and existing clients; and/or 
     perform ongoing CDD for existing clients; and/or
   • perform a comprehensive firm-wide risk assessment.
2. He failed to hold clients’ money in full compliance with paragraph 11 and paragraph 33(b) of AAT’s Clients’ Money Policy.
3. He failed to maintain the minimum level of professional indemnity insurance (PII) cover as set out in paragraph 5 of AAT’s PII Policy.
4. He submitted a licence renewal application wherein he answered “Yes” to the following statements:
   • “I am complying with my obligations under the Money Laundering Regulations in force and will comply with any anti-money laundering legislation (as it comes into force) in the exercise of providing accountancy services as an external accountant”
   • “I understand that all clients' money must be held in a client bank account and if I do hold clients' money, I will comply with my obligations under AAT's Clients' Money Policy”.
5. His conduct at Allegation 4 above was misleading.

By reason of the conduct set out in the Allegations above, Elliot Massey is guilty of misconduct pursuant to Article 21 of AAT’s Articles of Association.

Elliot Massey is hereby:

1. Severely reprimanded for a period of three years
2. Fined £3,500
3. Divested of his fellow member (FMAAT) status for a period of three years
4. Warned about his future conduct.

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.