Disciplinary outcome: Manaf Ahmed

1. He failed to carry out and/or document an adequate firm-wide money laundering risk assessment in contravention of Regulation 18 of the Money Laundering Regulations 2017.
2. He failed to have in place adequate Anti-Money Laundering policies, procedures and controls in contravention of Regulation 19 of the Money Laundering Regulations 2017.
3. He failed to carry out any or any adequate regular review of his Anti-Money Laundering policies, procedures, and controls in contravention of Regulation 21 of the Money Laundering Regulations 2017.
4. He failed to carry out any or any adequate client due diligence and verification in respect of one or more clients in contravention of Regulations 27 and 28 of the Money Laundering Regulations 2017.
5. He failed to receive and/or hold clients’ money in accordance with the provisions dictated by AAT’s Clients’ Money Policy.
6. He failed to maintain adequate records of his continuing professional development (CPD) activities in contravention of AAT’s CPD Policy.
7. He failed to have an adequate documented continuity of practice agreement in place in contravention of AAT’s Continuity of Practice Policy.

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

The Investigation Team orders that Manaf Ahmed is:

1. Fined £6,000.00
2. Severely reprimanded for a period of three years.
3. Removed from AAT fellow membership (FMAAT) status for a period of three 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.