Disciplinary outcome: Joanne Gardner

1. She failed to comply with her obligations under the relevant Money Laundering Regulations while providing accountancy services to the public, specifically:

• From an unknown date until on or around 17 June 2022, she failed to carry out any or any adequate periodic review of her Anti-Money Laundering policies, procedures and control; and/or
• From an unknown date until on or around 17 June 2022, she did not apply and/or record adequate client due diligence measures in respect of one or more clients; and/or
• From an unknown date until on or around 17 June 2022, she failed to carry out and/or record ongoing monitoring in respect of one or more clients; and/or
• From an unknown period up until on or around 08 March 2022, she failed to have in place adequate Anti-Money Laundering training for staff members and/or sub-contractors.

2. From an unknown date until on or around 17 June 2022, she failed to issue and – or any adequate – letters of engagement to one or more clients, in contravention of AAT’s Client Care policy.
3. From an unknown date until on or around 17 June 2022, she failed to receive and hold clients’ money in accordance with AAT’s Clients’ Money policy.
4. From an unknown date until on or around 17 June 2022 she failed to have in place any or any adequate continuity of practice agreement.

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

1. Severely reprimanded, with the severe reprimand to remain live on her record for a period of two years/24 months.
2. Fined £3,000.00.

Consent