Disciplinary outcome: Tanzeel Ur Rehman

1. He did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy or related services on a self-employed basis. Specifically, he failed to:
   • regularly perform and document a firm-wide risk assessment; and/or
   • conduct regular compliance reviews of his firm’s anti-money laundering policies, controls, and procedures; 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. He failed to issue letters of engagement to one or more clients that fully complied with paragraph 5 AAT’s Client Care Policy
3. He failed to issue required client disengagement letters to one or more clients, as mandated by AAT’s Client Care Policy
4. He failed to hold client funds in accordance with one or more provisions of AAT’s Clients’ Money Policy.

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

Tanzeel Ur Rehman is hereby:

1. Reprimanded for a period of four years
2. Fined £3,500
3. Deemed ineligible to hold fellow member (FMAAT) status for a period of four years
4. Warned about his 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.