Disciplinary outcome: Paula Scott

1. She failed to carry out an adequate firm-wide money laundering risk assessment.
2. She failed to apply adequate risk-based due diligence and ongoing monitoring measures in respect of one or more clients.
3. She failed to have in place adequate Anti-Money Laundering policies, procedures, and controls.
4. She failed to carry out any or any adequate periodic review of her Anti-Money Laundering policies, procedures, and controls.
5. She failed to issue any of any adequate letters of engagement to one or more clients in accordance with AAT’s Client Care Policy.
6. She failed to comply with Regulation 8.1.12. of AAT’s Licencing Regulations.

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

1. Fined £2,000.00.
2. Severely Reprimanded for two 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.