Disciplinary outcome: Paul Charles

1. No adequate anti-money laundering policies, procedures, and controls in place. 
2. No adequate procedures in place to report discrepancies in the People with Significant Control register.
3. No periodic review of the firm's anti-money laundering policies, procedures, and controls.
4. No adequate anti-money laundering training in place for relevant employees. 
5. Failed to apply adequate risk based due diligence and ongoing monitoring measures in respect of one or more clients. 

Grounds for disciplinary action existed and the matter was suitable for exercise of the Investigations team's powers under the Disciplinary Regulations.

1. Fined £5,000.00
2. Severely Reprimanded, for a period of two years
3. Removed of his fellow membership for a period of two years
4. Submitted to a practice assurance reviewed at his own expense

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.