Disciplinary outcome: Susan Joannou

1. Between 10 March 2021 until or around 2 April 2025, trading under Antony & Co Indemnity Services Limited, she provided self-employed accountancy services to the public without being registered with a supervisory authority as required within the Money Laundering Regulations.
2. For an unknown period until or around 14 March 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.
3. For an unknown period until on or around 14 March 2025 she failed to demonstrate and/or record adequate money laundering risk assessment(s) 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.
4. For an unknown period until or around 14 March 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.
5. For an unknown period until on or around 14 March 2025, she failed to receive and/or hold client monies in compliance with AAT’s Clients’ Money Policy as follows:

• She deducted £2,741.00 from the relevant client’s account without client consent to do so and/or prior to waiting until 30 days had elapsed after issuing an invoice, in breach of Section 28.
• She failed to ensure one or more client bank accounts were interest-bearing, in breach of Section 19.
• She failed to carry out and/or document an annual compliance review in breach of Section 33(b).

6. Between an unspecified time in 2021 to on or around 14 March 2025, she failed to meet AAT’s minimum requirements regarding professional indemnity insurance (PII) cover, breaching Section 5 of AAT’s Professional Indemnity Insurance (PII) Policy.

By reason of the conduct set out in the Allegations above, Susan Joannou 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 £6,000.00.
3. Removed of fellow membership status for a period of three years.

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.