Disciplinary outcome: Vikash Kukar

1. He failed to carry out an adequate firm-wide money laundering risk assessment in accordance with Regulation 18 of the Money Laundering Regulations 2017.
2. He failed to document or adequately document regular his Anti-Money Laundering policies, procedures, and controls in accordance with Regulation 19 of the Money Laundering Regulations 2017.
3. He failed to carry out any or any adequate regular review of his Anti-Money Laundering policies, procedures, and controls in accordance with Regulation of the Money Laundering Regulations 2017.
4. He failed to carry out an adequate risk assessment and ongoing monitoring in respect of one or more clients in accordance with Regulation 28 of the Money Laundering Regulations 2017.

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

The Investigation Team orders that Vikash Kukar be:

1. Fined £4,000
2. Severely Reprimanded for 2 years
3. FMAAT status removed 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.