Disciplinary outcome: Joseph David

1. He failed to issue letters of engagement to one or more clients that were fully compliant with paragraph 5 AAT’s Client Care Policy.
2. He provided Forensic Accounting, Limited Assurance Engagement, and Inheritance Tax whilst not licensed to do so.
3. He did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis. Specifically, he failed to: 
   •    apply to AAT for approval of two beneficial owner, officer, manager appointments; and/or 
   •    conduct a regular compliance review of his firm’s anti-money laundering policies, controls, and procedures; and/or
   •    formally document a risk assessment for one or more clients.
4. He failed to have a written continuity of practice agreement in place as is required under AAT’s Continuity of Practice Policy.

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

Joseph David is hereby:

1. Reprimanded for a period of three years
2. Fined £4,500
3. Deemed ineligible to hold fellow member (FMAAT) status for a period of three years
4. Warned about his future conduct.
    

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.