Disciplinary outcome: James Hinchliffe

James Hinchliffe’s conduct was found to be in breach of the Code of Professional Ethics and to have posed a risk to the public and/or undermine public confidence in the Association and its members as follows:
1. For an unknown period up until on or around 26 August 2021, he did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy services on a self-employed basis. Specifically, he failed to:
    a) apply to AAT for approval of a beneficial owner, officer, or manager for Graeme Hinchliffe Associates Ltd
    b) have in place procedures to report discrepancies to Companies House concerning persons of significant control in connection to limited company clients and/or limited liability partnership clients
    c)conduct adequate customer due diligence where clients were not met face to face
    d)employ an adequate risk-based approach to initial and ongoing customer due diligence
    e)undertake regular anti-money laundering training
2. On or around 21 April 2020 to on or around 26 August 2021, he failed to hold monies on behalf of one or more clients in full compliance with AAT’s Clients Money policy.
3. On dates unknown, he received commissions without notifying his clients and retained said commissions without obtaining client consent.
4. He failed to have in place a continuity of practice agreement in full compliance with AAT’s Continuity of Practice policy.
5. On dates unknown, he provided the service Budgeting and forecasting whilst not licensed to do so.
6. He failed to issue a letter of engagement to one or more clients in full compliance with AAT’s Client Care policy.

Grounds for disciplinary action existed and the matter was suitable for exercise of the Investigations Team's powers under the Disciplinary Regulations.

James Hinchliffe is hereby: 
1. Reprimanded; the reprimand will expire 24 months from the date of this Order
2. Fined £2,000
3. Warned about his future conduct.

Consent