Disciplinary outcome: Mouhamadou Konate

1. He did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy or bookkeeping services on a self-employed basis. Specifically, he 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
   • have in place any or any adequate procedures to report discrepancies to Companies House concerning persons of significant control in connection to limited company clients and/or limited liability partnership clients; and/or
   • conduct a regular compliance review of his firm’s AML controls; and/or
   • effectively perform and document client due diligence (CDD) for one or more clients; and/or
   • adequately document ongoing CDD for one or more existing clients; and/or
   • undertake any or any effective AML training.
2. He failed to register with the Information Commissioner's Office for data protection purposes.
3. He failed to issue letters of engagement that were fully compliant with paragraph 5 of AAT’s Client Care Policy.
4. He failed to have a written continuity of practice agreement in place as required under AAT’s Continuity of Practice Policy.
5. He provided Business Income Tax whilst not licensed to do so.
6. He submitted a licence renewal application wherein he answered “Yes” to the following statements:
   • “I am complying with my obligations under the Money Laundering Regulations in force and will comply with any other anti-money laundering legislation (as it comes into force) in the exercise of providing accountancy services as an external accountant”
   • “I have provided letters of engagement, which meet the requirements of AAT’s Client Care policy, to each client”
   • “I comply with my obligations under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 with any other anti-money laundering legislation (and any other data protection legislation as it comes into force). I have also paid my data protection fee to the Information Commissioners Office (ICO) and understand this must be renewed every 12 months”
   • “I am aware of and will adhere to the requirements of AAT’s Continuity of Practice policy”.
7. His conduct at Allegation 6 above was misleading.

By reason of the conduct set out in the Allegations above, Mouhamadou Konate 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 £4,772
3. Deemed unfit to hold fellow member status for a period of three years
4. Warned about his 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.