Disciplinary outcome: Stephenson Ottey

Order by consent

In the matter of

Stephenson Ottey FMAAT

Membership number



3 February 2023


Stephenson Ottey’s conduct was found to be in breach of the Code of Professional Ethics and to have posed a risk to the public and/or undermine public confidence in the Association and its members as follows:
1. For an unknown period up until on or around 04 August 2022, he did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy services on a self-employed basis. Specifically, he failed to:
a. have in place any or any adequate anti-money laundering policies or procedures 
b. carry out an adequate firm-wide risk assessment for one of his firms
c. carry out any or any adequate risk-based assessment as part of initial and ongoing client due diligence  
d. verify the identity of one or more clients
e. undertake regular anti-money laundering training
f. carry out a review of his anti-money laundering controls and procedures
2. Between on our around 14 February 2020 to between on or around 14 February 2022, he did not hold clients’ money in accordance with AAT’s Clients’ Money Policy 
3. For an unknown period up until on or around 13 January 2022, he failed to comply with AAT’s CPD Policy requirements
4. From 15 June 2020 up until on or around 09 January 2022, he failed to have professional indemnity insurance cover for the entity Global Associate Partners LLP
5. He failed to have in place a continuity of practice arrangement that conformed to AAT’s Continuity of Practice Policy
6. On dates unknown, he issued letters of engagement that were not fully compliant with AAT requirements 
7. He failed to issue a letter of engagement to one or more clients as is required under AAT’s Client Care Policy.


Grounds for disciplinary action existed and the matter was suitable for exercise of the Investigations Team's powers under the Disciplinary Regulations.


Stephenson Ottey is hereby:
1. Reprimanded for a period of 24-months 
2. Fined £3,800
3. Divested of his fellow member (FMAAT) status 
4. Warned about his future conduct. 


Stephenson Ottey consented to the decision of the Investigations Team in accordance with Regulation 6 of the Disciplinary Regulations.