Disciplinary outcome: Alan Swann

1. 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. document ongoing client due diligence (CDD) in every instance; and/or
   b. apply enhanced CDD measures with a client established in a high-risk third country.
2. He submitted a licence renewal application wherein he answered “Yes” to the statement, "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".
3. His conduct at Allegation 2 above was misleading.
4. He failed to maintain the minimum level of professional indemnity insurance (PII) cover as set out in paragraph 5 of AAT’s PII Policy.

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

Alan Swann is hereby:

1. Reprimanded for a period of three years
2. Fined £3,000
3. Deemed ineligible to hold fellow member (FMAAT) status for a period of three years
4. Warned about his future conduct.

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.