Disciplinary outcome: Tracy Rhys-Williams

1. She failed to have in place any or any adequate Anti-Money Laundering policies, procedures, and controls.
2. She failed to carry out and/or document an adequate firm-wide money laundering risk assessment.
3. She failed to carry out adequate client due diligence, risk assessment and ongoing monitoring in respect of one or more clients.
4. She failed to have in place adequate Anti-Money Laundering training for staff members and/or sub-contractors.
5. She failed to carry out any or any adequate regular review of her Anti-Money Laundering policies, procedures, and controls.
6. She failed to have in place any, or any adequate, agreement for continuity of practice.

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

1. £5,000.00 fine
2. Severely reprimanded for two 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.