Disciplinary outcome: Kim Redwood-Lee

1. She did not comply with her obligations under the Money Laundering Regulations in force while providing accountancy and/or bookkeeping services on a self-employed basis. Specifically, she failed to:
   • perform and document a firm-wide risk assessment; and/or
   • conduct a regular compliance review of her firm’s AML controls; and/or
   • effectively perform and document client due diligence (CDD) for one or more clients; and/or
   • document ongoing CDD for one or more existing clients.
2. She failed to hold client money in accordance with one or more provisions of AAT’s Clients’ Money Policy.
3. She failed to comply with AAT’s Continuing Professional Development (CPD) Policy, in that she failed to maintain adequate records of her CPD activities.
4. She failed to have a written continuity of practice agreement in place as required under AAT’s Continuity of Practice Policy.
5. She provided Capital Gains Tax and Limited Assurance Engagement whilst not approved to do so.

By reason of the conduct set out in the Allegation above, Kim Redwood-Lee is guilty of misconduct pursuant to Article 21 of AAT’s Articles of Association.

1. Reprimanded for a period of three years
2. Fined £4,000
3. Warned about her 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.