Disciplinary outcome: Essam El-Tahlawy

1. He did not comply with his obligations under the Money Laundering Regulations in force while providing bookkeeping services on a self-employed basis. Specifically, he failed to: 
   • regularly perform and document a firm-wide risk assessment; and/or
   • have in place any or any adequate anti-money laundering (AML) policies and procedures; and/or 
   • effectively perform and document initial client due diligence (CDD) for one or more new clients; and/or
   • adequately perform and document ongoing CDD for one or more existing clients; and/or
   • undertake any or any effective AML training for himself and staff.
2. He failed to maintain adequate records of continuing professional development (CPD) activities, as required under AAT’s CPD Policy.
3. He failed to have a written continuity of practice agreement in place as required under AAT’s Continuity of Practice Policy.
4. He provided Financial Accounts and Accounts Preparation for Statutory Purposes whilst not licensed to do so.

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

1. Reprimanded for a period of five years
2. Fined £3,500
3. Warned about his future conduct.

The decision of the Investigations Team shall stand as Order of the Association pursuant to Regulations 5.2 and 5.3 of the Disciplinary Regulations.