Disciplinary outcome: Simon Cook

1. He did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy and/or bookkeeping services on a self-employed basis. Specifically, he failed to:
   • perform and document an adequate firm-wide risk assessment; and/or
   • have in place documented anti-money laundering (AML) policies and procedures; and/or
   • conduct a regular compliance review of his firm’s AML controls; and/or
   • undertake effective AML training for himself and/or relevant staff; and/or
   • effectively perform and document client due diligence (CDD) for one or more new clients; and/or
   • adequately perform and document ongoing CDD for one or more existing clients.
2. Contrary to HMRC requirements, he failed to obtain and retain written approval from one or more clients before submitting
   tax returns to HMRC.
3. He failed to have a written continuity of practice agreement in place as required under AAT’s Continuity of Practice Policy.
4. He failed to maintain the minimum level of professional indemnity insurance (PII) as set out under paragraph 5.2 of AAT’s PII Policy.

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

1. Reprimanded for a period of three years
2. Fined £4,000
3. Deemed ineligible to hold fellow member (FMAAT) status for three years
4. Warned about his future conduct.

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.