Disciplinary outcome: Glenn Leathley

1. He failed to have in place any or any adequate procedures to report discrepancies to Companies House concerning persons of significant control in connection to limited company clients and/or limited liability partnership clients.
2. He failed to perform anti-money laundering (AML) risk assessments for one or more new clients.  
3. He failed to implement procedures to perform enhanced due diligence for one or more clients.  
4. He failed to implement any or any effective verification procedures for one or more clients.  
5. He failed to conduct a regular compliance review of his firm’s AML policies, controls, and procedures.
6. He failed to receive and/or hold clients’ money in a designated client bank account.
7. He failed to notify and obtain consent from clients in relation to commission or referral fees received. 

8. He submitted a completed licence renewal application, within which he answered ‘yes’ to each of the following statements:  

   a) I am complying with my obligations under the Money Laundering Regulations in force and will comply with any other anti-money laundering legislation (as it comes into force) in the exercise of providing accountancy services as an external accountant. 

   b) 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.  

   c) Are you carrying out customer due diligence on your clients including identifying and verifying who your clients are (including beneficial owners where relevant)?  

   d) Do you retain copies of client identification and verification evidence on file? 

9. His conduct at Allegation 8 above was misleading. 

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

Glenn Leathely is hereby: 

1. Fined £1,500
2. Severely Reprimanded for a period of 36 months
3. Removed of fellow status for a period of 36 months 

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.