Disciplinary outcome: Malgorzata Bak
Order by consent
In the matter of
Mrs Malgorzata Bak MAAT
Membership number
10352706
Date
05 June 2025
Misconduct
1. From an unknown date until on or around 18 January 2024, whilst a full member of AAT, she failed to apply adequate risk-based due diligence and ongoing monitoring measures in respect of one or more clients.
2. From an unknown date until on or around 18 January 2024, whilst a full member of AAT, she failed to carry out any or any adequate periodic review of her Anti-Money Laundering policies, procedures, and controls.
3. From an unknown date until on or around 18 January 2024, whilst a full member of AAT, she provided Trust and Company Service Providers (TCSP) services outside the scope of her license.
4. From an unknown date until on or around 18 January 2024, whilst a full member of AAT, she failed to have in place any or any adequate Continuity of Practice Agreement, in accordance with AAT’s Client Care policy.
Finding
By reason of the conduct set out in the Allegations above, Malgorzata Bak is guilty of misconduct pursuant to Article 21 of AAT’s Articles of Association.
Order
The Investigation Team orders that Malgorzata Bak be:
1. Fined £2,000
2. Severely Reprimanded for two years.
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.
