Disciplinary outcome: Ishmael Owarish

1. He failed to carry out any or any adequate client due diligence in respect of one or more clients in contravention of Regulations 27 and 28 of the Money Laundering Regulations 2017.
2. He failed to carry out adequate ongoing monitoring in respect of one or more clients in contravention of Regulation 28 of the Money Laundering Regulations 2017.
3. RSI Associates Ltd provided accounting and/or bookkeeping services to the public without being registered with a supervisory authority in contravention of Regulations 7 and 26 of the Money Laundering Regulations 2017.
4. He failed to ensure that RSI Associates Ltd had professional indemnity insurance (PII) policy coverage in place that met the minimum level stipulated in Paragraphs 5.2 and 5.3 of AAT’s Professional Indemnity Insurance (PII) Policy.

The Investigations Team finds that, by reason of the conduct set out in the allegations above, Ishmael Owarish has committed misconduct pursuant to Article 21 of AAT’s Articles of Association.

1. Fine of £3,000.00
2. Severe Reprimand, to remain live on the member’s record for a period of five years.
3. Removal of AAT fellow membership (FMAAT) status for a period of five years.

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