Disciplinary outcome: George Michael

1. He did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy and/or bookkeeping services on a self-employed basis. Specifically, he failed to:
   • apply to AAT for approval of two beneficial owner/officer/manager appointments; and/or
   • 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
   • conduct a regular compliance review of his firm’s AML policies, controls, and procedures; and/or
   • undertake any or any effective AML training; and/or
   • adequately document ongoing client due diligence for one or more existing clients.
2. He failed to hold client money in accordance with one or more provisions of AAT’s Clients’ Money Policy.
3. He failed to maintain an adequate record of continuing professional development (CPD) activities undertaken as is required under AAT’s CPD Policy.
4. He failed to issue letters of engagement to one or more clients that were fully compliant with paragraph 5 of AAT’s Client Care Policy.

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

1. Reprimanded for a period of three years
2. Fined £3,500
3. Divested of his fellow member 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 Associations pursuant to Regulations 5.2 and 5.3 of the Disciplinary Regulations.