Disciplinary outcome: Margaret Attwood

1. She did not comply with her obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis. Specifically, she failed to:
   • regularly perform and document a firm-wide risk assessment; and/or
   • have in place any or any adequate anti-money laundering (AML) policies and procedures; and/or
   • conduct a regular compliance review of her firm’s AML controls; and/or
   • undertake any or any effective AML training; and/or
   • apply to AAT for approval of a beneficial owner/officer/ manager appointment; and/or
   • effectively perform and document client due diligence (CDD) for one or more new clients; and/or
   • adequately perform and document ongoing CDD for one or more existing clients.
2. She failed to hold monies on behalf of one or more clients 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:
   • did not keep her practice management knowledge and skills up to date; and/or
   • failed to maintain adequate records of her CPD activities.
4. She failed to comply with AAT’s Continuity of Practice Policy, in that she did not provide, when requested, a copy of her written continuity of practice agreement.
5. She failed to comply with AAT’s Professional Indemnity Insurance Policy, in that she did not arrange run-off cover for M.J.B Accountancy Services Limited for a period of not less than six years following the cessation of the firm.
6. She provided the following seven services whilst not approved to do so:
   • Financial accounting and accounts preparation for sole traders and partnerships
   • Financial accounting and accounts preparation for statutory purposes
   • Business Income Tax
   • Capital Gains Tax
   • Limited Assurance Engagement
   • Independent Examinations
   • Company Secretarial Services (Trust or Company Services Provider (TCSP)).
7. She failed to issue letters of engagement to one or more clients that were compliant with paragraph 5 of AAT’s Client Care Policy.
8. Contrary to HMRC requirements, she failed to obtain and retain written approval from one or more clients before submitting tax returns to HMRC.
9. She failed to comply with the Charity Commission’s requirements for independent examinations, in that she:
   • did not include an Independent Examiner’s Report in charity accounts she examined; and/or
   • did not maintain working papers demonstrating compliance with section 145 of the Charities Act 2011 and the Charity Commission’s Examiners’ Guide.

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

1. Expelled from AAT for a period of three years 
2. Fined £7,500
3. Divested of her fellow member status
4. 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.