Disciplinary outcome: Simona Lupascu

1. She failed to adequately document customer identification and verification procedures applied to one or more existing clients, in accordance with Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
2. She failed to carry out, or adequately document, an effective risk assessment for one or more new and/or existing clients, in accordance with Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

3. From an unknown date until on or around 04 September 2025, she failed to comply with AAT’s Clients’ Money Policy, in that she failed to: 

   a) maintain client money in a separate and clearly identifiable client bank account, in accordance with Regulation 11; 

   b) keep adequate records of client money received, held and paid out, in accordance with Regulation 18;  

   c) carry out and retain adequate reconciliations of the client bank account, in accordance with Regulation 31; 

   d) ensure that client money was withdrawn only in accordance with the policy, in accordance with Regulation 33(b); 

   e) return client money promptly where there was no longer any proper reason to hold it, in accordance with Regulation 41. 

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

1. Severely reprimanded for three years.
2. Fined £2,500

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.