Disciplinary outcome: Nicola Gentle

1. She did not comply with her obligations under the Money Laundering Regulations in force while providing accountancy and/or bookkeeping services on a self-employed basis. Specifically, she failed to:
   • have in place any, or any adequate, procedures to report discrepancies to Companies House concerning persons of significant control in connection with limited company and/or limited liability partnership clients; and/or
   • 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
   • conduct regular compliance reviews of her firm’s AML controls; and/or
   • undertake any, or any effective, AML training; and/or
   • effectively perform and document client due diligence (CDD) for one or more new clients; and/or 
   • adequately perform and document ongoing CDD for one or more existing clients.
2. She failed to register with the Information Commissioner's Office for data protection purposes.
3. She failed to comply with AAT’s Professional Indemnity Insurance (PII) Policy, in that she:  
   • did not maintain the appropriate level of PII; and/or
   • failed to have the required run-off cover in place in respect of a previous sole practice.
4. She failed to issue letters of engagement that were fully compliant with paragraph 5.1 of AAT’s Client Care Policy.

By reason of the conduct set out in the Allegations above, Nicola Gentle 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 £4,000.00
3. Warned about her 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.