Disciplinary outcome: Olivia Warrener-Davison

1. She did not comply with her obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis. Specifically, she failed to:
   • sufficiently document checks undertaken of the Persons of Significant Control register; and/or
   • conduct a regular compliance review of her firm’s anti-money laundering policies, controls, and procedures; and/or
   • adequately document her firm’s client due diligence measures
2. She submitted a licence renewal application wherein she answered “Yes” to the statement, “I am complying with my obligations under the Money Laundering Regulations in force and will comply with any anti-money laundering legislation (as it comes into force) in the exercise of providing accountancy services as an external accountant”.
3. Her conduct at Allegation 2 above was misleading.
4. She failed to fulfil her assurance to AAT of notifying her clients of certain omissions in her letter of engagement.

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

Olivia Warrener-Davison is hereby:

1. Reprimanded for a period of three years
2. Fined £2,500
3. Deemed ineligible to hold fellow member (FMAAT) status for a period of three years
4. 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.