Disciplinary outcome: Joshua Thomson

1. He failed to adequately review and/or document discrepancies in the Persons with Significant Control register in breach of Regulation 30A of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
2. He failed to record adequate customer due diligence (know your client) documentation regarding client identification in respect of one or more clients, in breach of Regulation 28(16) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
3. He failed to demonstrate and/or record adequate money laundering risk assessments for new and existing clients, in breach of Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
4. He failed to carry out and/or document ongoing monitoring in respect of one or more clients in breach of Regulation 28(11) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
5. He offered credit brokering services without appropriate authorisation, in breach of the Financial Services and Markets Act 2000.
6. He has been providing or holding himself out as providing limited assurance engagement services without being licensed by AAT to do so, in breach of Regulation 6.4 of AAT’s Licensing Regulations.

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

1. Severely reprimanded for a period of three years.
2. Fined £10,000.00.

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.