Disciplinary outcome: Paul Holt

1. No firm-wide risk assessment was in place
2. No procedures for reporting discrepancies in the Persons with Significant Control register was in place  
3. No regular review of AML policies, controls and procedures was carried out
4. No effective AML training was in place
5. No money laundering risk assessment was performed for new and existing clients
6. No ongoing customer due diligence for existing clients was completed
7. The documentation for client identification (know your client) was ineffective  
8. From an unknown date period up until or around 03 January 2024, he failed to comply with regulations (9)(b) of AAT’s Clients’ Money policy by using his clients’ money account to receive and pay funds for a client, but these funds were not related to an accountancy and/or bookkeeping services. 

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

Paul Holt is hereby:

1. Severely reprimanded for a period of three years
2. Fined £4,000

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.