Disciplinary outcome: Wendy Crayden
Order by consent
In the matter of
Wendy Crayden FMAAT
24 April 2023
Wendy Crayden’s conduct was found to be in breach of the Code of Professional Ethics and to have posed a risk to the public and/or undermine public confidence in the Association and its members as follows:
1. For an unknown period up until on or around 22 August 2022, she did not comply with her obligations under the Money Laundering Regulations in force while providing accountancy services on a self-employed basis. Specifically, she failed to:
a. perform and document a firm-wide risk assessment
b. have in place any or any adequate anti-money laundering policies or procedures
c. carry out any or any adequate risk-based assessment as part of initial and ongoing client due diligence
d. verify the identity of one or more clients
e. ensure relevant employees undertook regular anti-money laundering training
f. carry out a review of her anti-money laundering controls and procedures
2. For an unknown period, she provided Limited Assurance Engagement whilst not licensed to do so
3. She failed to issue a letter of engagement to one or more clients as is required under AAT’s Client Care Policy
4. She failed to have a continuity of practice arrangement in place that conformed to AAT’s requirements.
Grounds for disciplinary action existed and the matter was suitable for exercise of the Investigations Team's powers under the Disciplinary Regulations.
Wendy Crayden is hereby:
1. Reprimanded for a period of 24-months
2. Fined £2,500
3. Divested of her fellow member (FMAAT) status
4. Warned about her future conduct.
Wendy Crayden passively consented to the decision of the Investigations Team in accordance with Regulation 6 of the Disciplinary Regulations.