Disciplinary outcome: Thillaiampalam Suthaharan

1. He failed to have in place adequate Anti-Money Laundering policies, procedures, and controls in accordance with Regulation 19.
2. He failed to carry out an adequate risk assessment and ongoing monitoring in respect of one or more clients in accordance with Regulation 28.
3. He did not have sufficient Professional Indemnity Insurance (PII) in accordance with AAT’s Professional Indemnity Insurance policy.  

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

The Investigation Team orders that Thillaiampalam Suthaharan be:  

1. Fined £4,000.
2. Severely Reprimanded for 2 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.