Disciplinary outcome: Zoe Tanner

1. For an unknown period up until on or around 6 January 2026 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.
2. For an unknown period until on or around 6 January 2026 she failed to adequately review and/or document discrepancies in the Persons with Significant Control register in breach of Regulation 30A of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
3. For an unknown period until or around 6 January 2026, she failed to carry out a regular review of anti-money laundering policies, controls and procedures in breach of Regulation 21 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
4. For an unknown period until or around 6 January 2026, she failed to demonstrate adequate customer due diligence measures, in breach of Regulation 28 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
5. For an unknown period until or around 6 January 2026 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.
6. For an unknown period until or around 6 January 2026 she failed to maintain professional competence through continuing professional development (CPD) and/or provide evidence of such compliance, in breach of AAT’s CPD Policy.
7. 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.
8. For an unknown period until or around 6 January 2026, she has been providing or holding herself out as providing limited assurance engagement services whilst not being licensed by AAT to do so, in breach of Regulation 6 of AAT’s Licensing Regulations.
9. For an unknown period until or around 6 January 2026, she has failed to provide an adequate engagement letter to one or more clients, in breach of AAT’s Client Care Policy.

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

1. Severely reprimanded for a period of three years.
2. Fined £8,000.00.

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.