Disciplinary outcome: Kevin Bennett

1. He failed to carry out an adequate firm-wide money laundering risk assessment.
2. He failed to document his Anti-Money Laundering policies, procedures, and controls.
3. He failed to carry out any or any adequate periodic review of his Anti-Money Laundering policies, procedures, and controls.
4. He failed to carry out an adequate risk assessment and ongoing monitoring in respect of one or more clients.
5. He failed to register a connected entity for Anti-Money Laundering supervision.
6. He failed to have a continuity of practice agreement documented in writing.

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

1. Fined £5,000.00.
2. Severely Reprimanded for five 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.