Disciplinary outcome: Robin Leathley

1. He failed to have in place any or any adequate procedures to report discrepancies to Companies House concerning persons of significant control in connection to limited company clients and/or limited liability partnership clients.
2. He failed to perform anti-money laundering (AML) risk assessments for one or more new clients.
3. He failed to implement procedures to perform enhanced due diligence for one or more clients.
4. He failed to implement any or any effective verification procedures for one or more clients.
5. He failed to conduct a regular compliance review of his firm’s AML policies, controls, and procedures.
6. He failed to receive and/or hold clients’ money in a designated client bank account.
7. He received commissions without notifying his clients’ and retained said commissions without obtaining his clients’ consent.
8. He failed to adequately document an independent examination of charity accounts in accordance with the Charity Act 2011.
9. He failed to keep his professional knowledge and skills up to date and failed to keep a CPD record.
10. He failed to have any or any adequate continuity of practice agreement in place.
11. He submitted a completed annual declaration, wherein he answered ‘yes’ to the statement, I am compliant with AAT’s CPD policy.
12. He submitted a completed licence reinstatement application, within which he answered ‘yes’ to each of the following statements:
    • I am complying with my obligations under the Money Laundering Regulations in force and will comply with any other anti-money laundering legislation (as it comes into force) in the exercise of providing accountancy services as an external accountant.
    • I am aware of and will adhere to the requirements of AAT’s Continuity of Practice policy.
    • I understand that all clients' money must be held in a client bank account and if I do hold clients' money, I will comply with my obligations under AAT's Clients' Money policy.
13. His conduct at Allegation 11 to 12 above was misleading,

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

1. Fined £3,600.00
2. Severely Reprimanded for a period of three years
3. Removed of his fellow membership for a period of three 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.