Disciplinary outcome: Malgorzata Bak

Order by consent

In the matter of

Mrs Malgorzata Bak MAAT

Membership number

10352706

Date

05 June 2025

Misconduct

  1. She failed to apply adequate risk-based due diligence and ongoing monitoring measures in respect of one or more clients.
  2. She failed to carry out any or any adequate periodic review of her Anti-Money Laundering policies, procedures, and controls.
  3. She provided Trust and Company Service Providers (TCSP) services outside the scope of her license.
  4. 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

1. Fined £2,000.00.
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.