Disciplinary outcome: James McLen

1. He failed to carry out and/or document an adequate firm-wide money laundering risk assessment in contravention of Regulation 18 of the Money Laundering Regulations 2017.
2. He failed to carry out any or any adequate regular review of his Anti-Money Laundering policies, procedures, and controls in contravention of Regulation 21 of the Money Laundering Regulations 2017.
3. He failed to have any or any adequate procedure in place for reporting discrepancies in the Persons with Significant Control register in contravention of Regulation 30 of the Money Laundering Regulations 2017.
4. He failed to carry out any or any adequate client due diligence and verification in respect of one or more clients in contravention of Regulations 27 and 28 of the Money Laundering Regulations 2017.
5. He failed to carry out an adequate risk assessment and ongoing monitoring in respect of one or more clients in contravention of Regulation 28 of the Money Laundering Regulations 2017.
6. He failed to receive and/or hold clients’ money in accordance with the provisions dictated by AAT’s Clients’ Money Policy.
7. He failed to have any or any adequate professional indemnity insurance coverage for one or more of your firms in contravention of AAT’s Professional Indemnity Insurance (PII) Policy.

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

The Investigations Team orders that James McLen is:

1. Fined of £6,000.00
2. Severely reprimanded for a period of three years.

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.