Disciplinary outcome: Mark Thomas

Mark Thomas' 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 08 August 2023, he did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis. Specifically, he failed to: 
   a. complete any or any adequate firm-wide risk assessment; and/or
   b. have any or any adequate documented anti-money laundering (AML) policies and procedures in place; and/or 
   c. carry out a review of his firms' AML policies, controls, and procedures 
2. For an unknown period up until on or around 19 April 2023, he acted as a trust or company service provider without being licensed by AAT to do so
3. For an unknown period up until on or around 01 February 2023, he did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis in that he failed to document a risk assessment for new clients. 
4. For an unknown period up until on or around 01 February 2023, he failed to hold clients’ money in full compliance with AAT’s Clients Money Policy. 

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

Mark Thomas is hereby:

1. Reprimanded for a period of three years
2. Fined £2,500
3. Warned about his future conduct.

Consent