Disciplinary outcome: Kim Richards

Kim Richards’ conduct was found to be in breach of the Code of Professional Ethics and to have posed a risk to the public and/or undermine public confidence in the Association and its members as follows:

1. For an unknown period up until on or around 14 April 2022, she did not comply with her obligations under the Money Laundering Regulations in force while providing accountancy services on a self-employed basis. Specifically, she failed to:
   a. carry out a firm-wide risk assessment
   b. employ an adequate risk-based approach to initial and ongoing customer due diligence
   c. have in place any or any adequate anti-money laundering policies or procedures 
   d. carry out a review of her anti-money laundering controls
2. For an unknown period up until on or around 14 April 2022, she failed to comply with her obligations under AAT’s Clients Money Policy
3. She failed to issue a letter of engagement to one or more clients in full compliance with AAT’s Client Care policy.

Grounds for disciplinary action existed and the matter was suitable for exercise of the Investigations Team's powers under the Disciplinary Regulations.
 

Kim Richards is hereby:

1. Reprimanded for a period of two years
2. Deemed ineligible to hold fellow membership status whilst the reprimand is active
3. Fined £1,300
4. Warned about her future conduct.

Consent