Disciplinary outcome: Imran Tahirkheli

1. He failed to have in place adequate anti-money laundering (AML) policies, procedures, and controls. 
2. He failed to carry out any or any adequate client due diligence in respect of one or more clients.
3. He failed to carry out an adequate risk assessment and ongoing monitoring in respect of one or more clients. 
4. He failed to carry out an adequate firm-wide money laundering risk assessment. 
5. He failed to carry out any or any adequate periodic review of his AML policies, procedures, and controls. 
6. He failed to have in place adequate AML training for staff members and/or sub-contractors. 
7. He provided Personal Income Tax and Business Income Tax services outside the scope of his AAT licence. 
8. He failed to issue any or any adequate letters of engagement to one or more clients. 
9. He failed to have in place any or any adequate continuity of practice agreement. 

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

1. Severely reprimanded for a period of three years.
2. Fined £5,000.

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.