Disciplinary outcome: Pauline Sowemimo

Pauline Sowemimo’s professional or personal conduct, was found to be in breach of the Code of Professional Ethics and to have posed a risk to the public or was likely to undermine public confidence in the Association or its members; namely:
1. From an unknown date until on or around 26 August 2022, whilst a full member of AAT, Pauline Sowemimo failed to apply adequate risk-based due diligence and ongoing monitoring measures in respect of one or more clients.
2. From an unknown date until on or around 26 August 2022, whilst a full member of AAT, Pauline Sowemimo failed to not carry out and/or record an adequate firm-wide money laundering risk assessment.
3. From an unknown date until on or around 26 August 2022, whilst a full member of AAT, Pauline Sowemimo did not maintain an adequate written record of her anti-money laundering policies, controls and procedures.
4. From an unknown date until on or around 26 August 2022, whilst a full member of AAT, Pauline Sowemimo, did not carry out an adequate review of her anti-money laundering policies, controls and procedures.
5. From an unknown date until on or around 26 August 2022, whilst a full member of AAT, Pauline Sowemimo failed to issue any or any adequate letters of engagement to one or more clients, in accordance with AAT’s Client Care policy.
6. From an unknown date until on or around 20 July 2022, whilst a full member of AAT, Pauline Sowemimo did not open a clients’ money account, in accordance with regulation 10 of AAT’s Clients’ Money policy.

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

Pauline Sowemimo is hereby:
i. Fined £2,500.
ii. Severe Reprimand to remain on her record for a period of two years.
iii. Divested of FMAAT status for a period of two years.

Consent