Disciplinary outcome: Michael McCullion
Order by consent
In the matter of
Michael McCullion FMAAT
21 November 2022
Michael McCullion’s 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 18 February 2022, he did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy services on a self-employed basis. Specifically, he failed to:
a. apply to AAT for approval of a beneficial owner, officer, or manager for BI Accountancy Ltd
b. have in place procedures to report discrepancies to Companies House concerning persons of significant control in connection to limited company clients and/or limited liability partnership clients
c. conduct adequate initial client due diligence (CDD)
d. conduct adequate ongoing CDD
e. document an initial or ongoing risk assessment for one or more client
2. On dates unknown, he issued letters of engagement that were not fully compliant with AAT requirements
3. He failed to issue a letter of engagement to one or more clients as is required under AAT’s Client Care Policy
4. He failed to issue a disengagement letter to one or more clients as is required under AAT’s Client Care Policy
5. On dates unknown, he received commissions without notifying his clients and retained said commissions without obtaining client consent.
Grounds for disciplinary action existed and the matter was suitable for exercise of the Investigations Team's powers under the Disciplinary Regulations.
Michael McCullion is hereby:
1. Reprimanded for a period of 24-months
2. Fined £2,000
3. Warned about his future conduct.
Michael McCullion consented to the decision of the Investigations Team in accordance with Regulation 6 of the Disciplinary Regulations.