Disciplinary outcome: Susan Townsend

1. She did not comply with her obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis. Specifically, she failed to:
   • have in place any or any adequate procedures to report discrepancies to Companies House concerning persons of significant control in connection to limited company clients and/or limited liability partnership clients; and/or
   • regularly perform and document a firm-wide risk assessment; and/or
   • have in place any or any adequate anti-money laundering (AML) policies and procedures; and/or 
   • conduct a regular compliance review of her firm’s AML controls; and/or
   • undertake any or any effective AML training; and/or
   • effectively perform and document client due diligence (CDD) for one or more new clients; and/or 
   • adequately perform and document ongoing CDD for one or more existing clients.
2. She failed to register with the Information Commissioner's Office for data protection purposes.
3. She failed to issue letters of engagement to one or more clients that were compliant with paragraph 5.1 of AAT’s Client Care Policy.
4. She failed to issued disengagement letter in accordance with paragraphs 5.9 and 5.10 of AAT’s Client Care Policy.
5. She failed to comply with AAT’s Continuing Professional Development (CPD) Policy, in that she:
   • did not keep her practice management knowledge and skills up to date; and/or
   • failed to maintain adequate records of her CPD activities.
6. She failed to notify clients of the absence of a continuity of practice agreement or obtain their agreement to proceed without such cover thereby breaching paragraph 5.7 of AAT’s Continuity of Practice Policy.
7. She failed to maintain the minimum level of Professional Indemnity Insurance (PII) required under paragraph 5.2 of AAT’s PII Policy.

By reason of the conduct set out in the Allegations above, Sandra Townsend 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 £5,000.
3. Deemed ineligible to hold fellow member (FMAAT) status for three years.
4. Warned about her future conduct.

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.