Disciplinary outcome: Jay Wilson

1. He failed to perform a firm-wide risk assessment for Jaccountancy (UK) Limited.
2. He failed to have any documented anti-money laundering (AML) policies, controls and procedures in place for Jaccountancy (UK) Limited.
3. He failed to carry out a regular review of his AML policies, controls and procedures for Jaccountancy (UK) Limited.
4. He failed to document a risk assessment as part of initial client due diligence (CDD), for one or more clients of Jaccountancy (UK) Limited.
5. He failed to perform any or any adequate ongoing CDD for one or more clients of Jaccountancy (UK) Limited
6. He failed to implement effective client identification and verification procedures for one or more clients of Jaccountancy (UK) Limited. 
7. He failed to ensure that relevant staff at Jaccountancy (UK) Limited received regular AML training. 
8. He received commissions without notifying relevant clients of Jaccountancy (UK) Limited and retained said commissions without obtaining client consent.   
9. He failed to have in place a continuity of practice agreement in place for Then Tax Refunds Limited.
10. He failed to hold clients’ money for both entities in full compliance of paragraphs 9a and 11d of AAT’s Clients’ Money Policy. 
11. He misled the Association in respect of his compliance by submitting an incorrect licence renewal application wherein he answered “Yes” to the following statements:
    • “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”.
    • “I am aware of and will adhere to the requirements of AAT’s Continuity of Practice Policy”. 
    • “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”. 

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

1. Reprimanded for a period of three years
2. Fined £6,500
3. Ineligible to apply for fellow member (FMAAT) 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.