Disciplinary outcome: Paul Charles

1. He failed to have in place adequate Anti-Money Laundering policies, procedures, and controls.  
2. He failed to have adequate procedures in place for reporting discrepancies in registers.  
3. He failed to carry out adequate reviews of your Anti-Money Laundering policies, procedures, and controls.  
4. He did not have adequate anti money laundering training in place for your relevant employees.  
5. He failed to apply adequate risk based due diligence and ongoing monitoring measures in respect of one or more clients. 

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

1. Fine £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.