Disciplinary outcome: Michael Grant

1. For an unknown period until on or around 27 May 2025 he failed to conduct criminal record checks for two individuals considered to be a beneficial owner, officer or manager, in breach of Regulation 26 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
2. For an unknown period until or around 27 May 2025 he failed to demonstrate adequate customer due diligence measures including effective verification procedures for two clients, in breach of Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
3. For an unknown period until or around 27 May 2025 he failed to carry out and/or document ongoing monitoring in respect of one or more existing clients in breach of Regulation 28(11) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
4. On an unspecified date he issued and signed an audit report without being a registered auditor, in breach of Section 503 of the Companies Act 2006.
5. For an unknown period until on or around 27 May 2025 he failed to receive and/or hold client monies in accordance with the requirements of AAT's Clients' Money policy.
6. For an unknown period until on or around 27 May 2025, he failed to have suitable procedures in place to ensure adequate disclosure for one or more charity accounts. Consequently, he failed to ensure that one or more clients received competent professional service, in breach of Section 130 of AAT’s Code of Professional Ethics.

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

1. Severely reprimanded for a period of three years.
2. Fined £9,000.00.

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.