Disciplinary outcome: Zara Wilson
Order by consent
In the matter of
Mrs Zara Wilson MAAT AATQB
Business name
Robson Downing Ltd
Membership number
20054526
Date
21 August 2026
Misconduct
- For an unknown period up until on or around 24 September 2025 she failed to carry out and/or record an adequate firm-wide money laundering risk assessment in breach of Regulation 18 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
- For an unknown period until or around 24 September 2025, she failed to demonstrate adequate customer due diligence measures for one or more clients, in breach of Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
- For an unknown period until or around 24 September 2025, she failed to carry out and/or document ongoing monitoring in respect of one or more existing clients in breach of Regulation 28(11) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
- For an unknown period until on or around 24 September 2025, she failed to apply appropriate customer due diligence measures in respect of one or more clients, in breach of Regulation 35 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
- For an unknown period, she failed to demonstrate adequate arrangement for continuity of practice in accordance with the requirements of AAT’s Continuity of Practice Policy.
Finding
By reason of the conduct set out in the Allegations above, Zara Wilson is guilty of misconduct pursuant to Article 21 of AAT’s Articles of Association.
Order
- Severely reprimanded for a period of three years.
- Fined £2,500.00.
- Removed of fellow membership status for a period of three years.
Consent
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.
