Disciplinary outcome: Snezhana Andonova

1. For an unknown period up until on or around 10 July 2025 she failed to carry out and/or record an adequate firm-wide money laundering risk assessment in breach of Regulation 18 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
2. For an unknown period until on or around 10 July 2025 she failed to document anti-money laundering policies, controls and procedures in breach of Regulation 19 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
3. For an unknown period until or around 10 July 2025, she failed to carry out a regular review of anti-money laundering policies, controls and procedures in breach of Regulation 21 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
4. For an unknown period until or around 10 July 2025, she failed to demonstrate effective verification procedures for one or more clients in relation to customer due diligence measures, in breach of Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
5. For an unknown period until or around 10 July 2025, she failed to carry out and/or document ongoing monitoring in respect of one or more existing clients in breach of Regulation 28(11) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
6. For an unspecified period, she acted as a trust or company service provider (TCSP) without being licensed by AAT or registered with HMRC as a relevant person to do so, in breach of Regulation 56 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
7. During a period between 2022 and 2025, she failed to meet AAT’s minimum requirements regarding professional indemnity insurance (PII) cover, breaching AAT’s Professional Indemnity Insurance (PII) Policy.
8. For an unknown period until or around 10 July 2025 she failed to demonstrate adequate arrangement for continuity of practice in accordance with the requirements of AAT’s Continuity of Practice Policy.
9. For an unknown period, she has been providing and/or holding herself out as providing the following services whilst not being licensed by AAT to do so, in breach of Regulation 6 of AAT’s Licensing Regulations:

• Personal Income Tax; and/or,
• Trust or Company Secretarial Services (TCSP)

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

1. Severely reprimanded for a period of three years.
2. Fined £2,000.00.

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.