Disciplinary outcome: Paul Swift

1. He failed to have in place adequate Anti-Money Laundering policies, procedures and controls in contravention of Regulation 19 of the Money Laundering Regulations 2017.
2. He failed to carry out any – or any adequate – regular review of his Anti-Money Laundering policies, controls and procedures in contravention of Regulations 19 and 21 of the Money Laundering Regulations 2017. 
3. He failed to carry out adequate ongoing monitoring for one or more clients in contravention of Regulation 28 of the Money Laundering Regulations 2017.
4. He failed to carry out any – or any adequate – client due diligence in respect of one or more clients in contravention of Regulations 27 and 28 of the Money Laundering Regulations 2017.

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

The Investigations Team orders that Paul Swift is:

1. Fined £5,500.00
2. Severely reprimanded for a period of five years.
3. Declared ineligible to hold AAT fellow membership for a period of five years.

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.