Disciplinary outcome: Sara Brown

1. She failed to have any or any adequate procedures for reporting discrepancies in the Persons with Significant Control Register, in contravention of Regulation 30A of the Money Laundering Regulations 2017.
2. She failed to ensure the provision of adequate Anti-Money Laundering training to staff and/or subcontractors in contravention of Regulation 24 of the Money Laundering Regulations 2017.
3. She failed to carry out any or any adequate client due diligence and/or risk assessment in respect of one or more clients in contravention of Regulation 28 of the Money Laundering Regulations 2017.
4. She failed to carry out adequate ongoing monitoring in respect of one or more clients in contravention of Regulation 28 of the Money Laundering Regulations 2017.
5. She failed to ensure that Bookkeeping Bureau Accountancy Services Ltd had professional indemnity insurance (PII) policy coverage in place that met the minimum level stipulated in Paragraphs 5.2 and 5.3 of AAT’s Professional Indemnity Insurance (PII) Policy.
6. She provided budgeting and forecasting services to clients without being licensed by AAT to do so, in contravention of Regulation 6.4 of AAT’s Licensing Regulations.

The Investigations Team finds that, by reason of the conduct set out in the  allegations above, Sara Brown has committed misconduct pursuant to Article 21 of AAT’s Articles of Association.

1. Fine of £3,500.00
2. Severe Reprimand, to remain live on the member’s record for a period of two years.
3. Removal of AAT fellow membership (FMAAT) status for a period of two years

The decision of the Investigations Team shall stand as an Order of the Association pursuant to Regulation 5.3 of the Disciplinary Regulations.