Disciplinary outcome: Fabrize Meneguello

1. She did not comply with obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis. In particular, she failed to:
   • have in place any documented anti-money laundering (AML) policies and procedures; and
   • conduct regular compliance reviews of her firm’s AML controls.
2. She failed to have a written continuity of practice agreement in place, as required by AAT’s Continuity of Practice Policy.
3. She failed to comply with AAT’s Professional Indemnity Insurance (PII) Policy, in that she:
   • did not maintain the appropriate level of PII; and 
   • failed to hold PII that was fully retroactive
4. She provided Personal Income Tax services while not licensed by AAT to do so, contrary to paragraph 6.4 of AAT’s Licensing Regulations.
5. She failed to comply with AAT’s Client Care Policy, in that she:
   • failed to issue letters of engagement to all clients; and
   • issued letters of engagement that were not fully compliant with paragraph 5.1 of that Policy.

By reason of the conduct set out in the Allegations above, Fabrize Meneguello committed misconduct pursuant to Article 21 of AAT’s Articles of Association.

1. Reprimanded for a period of two years.
2. Fined £3,500.00.
3. Warned about her 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.