Disciplinary outcome: Aaron McLeish

Aaron McLeish'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 03 July 2024, he did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis. Specifically, he failed to:
   a. conduct a regular compliance review of his firm’s anti-money laundering (AML) policies, controls, and procedures; and/or
   b. undertake any or any effective AML training; and/or
   c. perform ongoing client due diligence for one or more existing clients.
2. For an unknown period up until on or around 26 July 2023, he failed to hold clients’ money in full compliance with paragraph 33(b) and paragraph 39 of AAT’s Clients Money Policy.
3. On or around 16 March 2023, he submitted a licence renewal application wherein he answered “Yes” to the following statements:
   a. “I am complying with my obligations under the Money Laundering Regulations in force and will comply with any anti-money laundering legislation (as it comes into force) in the exercise of providing accountancy services as an external accountant”
   b. “I understand that all clients’ money must be held in a client bank account and if I do hold clients’ money, I will comply with my obligations under AAT’s Clients’ Money Policy”.
4. His conduct at Allegation 3 above was misleading.

Grounds for disciplinary action existed and the matter was suitable for exercise of the Investigations Team's powers under the Disciplinary Regulations.

Aaron McLeish is hereby:

1. Reprimanded for a period of two years
2. Fined £2,500
3. Divested of his fellow member status for a period of two years
4. Warned about his future conduct.

Consent