Disciplinary outcome: Karen Brewer
Order by consent
In the matter of
Mrs Karen Brewer MAAT
Business name
Howard Smith & Co Ltd
Membership number
10153143
Date
29 April 2026
Misconduct
- For an unknown period until on or around 8 July 2025 she failed to demonstrate and/or record adequate money laundering risk assessments for one or more clients, in breach of Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
- For an unknown period until on or around 8 July 2025 she failed to record adequate customer due diligence documentation regarding client identification (know your client) in respect of one or more clients, in breach of Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
- For an unknown period until or around 8 July 2025 she failed to carry out and/or document ongoing monitoring in respect of one or more existing clients in breach of Regulation 28(11) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
Finding
By reason of the conduct set out in the Allegations above, Karen Brewer is guilty of misconduct pursuant to Article 21 of AAT’s Articles of Association.
Order
- Severely reprimanded for a period of three years.
- Fined £1,500.00.
Consent
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.
