Disciplinary outcome: Sunita Mehta

1. For an unknown period up until on or around 3 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 3 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 on or around 3 July 2025 she failed to adequately review and/or document discrepancies in the Persons with Significant Control register in breach of Regulation 30A of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
4. For an unknown period until on or around 3 July 2025 she failed to conduct and/or document effective anti-money laundering training for relevant staff, in breach of Regulation 24 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
5. For an unknown period until or around 3 July 2025 she failed to carry out and/or document ongoing monitoring in respect of one or more 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 unknown period until on or around 3 July 2025 she failed to record adequate customer due diligence (know your client) documentation regarding client identification in respect of one or more clients, in breach of Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
7. For an unknown period until on or around 3 July 2025 she failed to demonstrate and/or record adequate money laundering risk assessments for one or more clients, in breach of Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
8. For an unknown period, she has been acting as a trust or company service provider without being registered with HMRC to do so, in breach of Regulation 56 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
9. For an unknown period, she has been providing or holding herself out as providing Company Secretarial Services (TCSP) whilst not being licensed by AAT to do so, in breach of Regulation 6.4 of AAT’s Licensing Regulations 2024.

By reason of the conduct set out in the Allegations above, Sunita Mehta 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 £5,500.00.

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.