Disciplinary outcome: Michael Hurst

1. 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.
2. 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.
3. He failed to carry out adequate ongoing monitoring in respect of one or more clients in contravention of Regulation 28 of the Money Laundering Regulations 2017.
4. He failed to provide adequate Anti-Money Laundering training for staff members and/or sub-contractors in contravention of Regulation 24 of the Money Laundering Regulations 2017.
5. He failed to ensure his professional indemnity insurance (PII) policy coverage met the minimum level stipulated in Paragraphs 5.2 and 5.3 of AAT’s Professional Indemnity Insurance (PII) Policy.

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

1. Fined £5,000.00
2. Severely reprimanded for five years.
3. Removed from AAT fellow membership (FMAAT) status for five 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.