Disciplinary outcome: Amanda Towers

1. For an unknown period up until on or around 21 August 2018 she failed to have in place adequate Anti-Money Laundering procedures
2. For an unknown period up until on or around 21 August 2018 she failed to carry out an adequate firm-wide money laundering risk assessment
3. For an unknown period up until on or around 21 August 2018 she failed to have in place adequate Anti-Money Laundering training for staff members
4. For an unknown period up until on or around 21 August 2018 she failed to carry out any or any adequate review of Anti-Money Laundering procedures
5. For an unknown period up until on or around 21 August 2018 she failed to carry out any or any
   adequate client due diligence in respect of one or more clients
6. For an unknown period up until on or around 21 August 2018 she failed to adequately record the carrying out of client due diligence in respect of one or more clients
7. For an unknown period up until on or around 21 August 2018 she failed to issue any or any
   adequate letters of engagement to one or more clients
8. For an unknown period up until on or around 21 August 2018 she failed to have in place any or any adequate continuity of practice agreement
9. On or around 14 August 2017 she submitted a completed AAT Licensed Accountant renewal form to AAT, wherein she answered "yes" to each of the following questions:
   1. If you use subcontractors, do you have written arrangements specifying responsibilities,
      supervision and requirements for independence, confidentiality and competence?"
   2. "Are you carrying out customer due diligence on your clients including identifying and
      verifying who your clients are (including beneficial owners where relevant)?"
   3. "Are copies of identification and verification evidence on file?"
   4. "Do you have appropriate policies or procedures for…reporting knowledge or suspicion of
      money laundering?"
   5. "Do you have appropriate policies or procedures for…record keeping?"
   6. "Do you have appropriate policies or procedures for…internal controls?"
   7. "Do you have appropriate policies or procedures for…risk assessment and
      management?"
   8. "Are records maintained of matters reported to the MLRO and any action taken?"
   9. "Are procedures in place to cover external reports to the NCA?"
   10. "Do you have a quality control process to ensure everyone is complying with these
       policies and procedures?"
   11. "Have all principals and staff received anti-money laundering training?"
   12. "I provide letters of engagement to all clients"
   13. "I deliver my services in compliance with the Provision of services Regulations"
10. Her answers to the questions set out in paragraph 9 above were:
    1. Misleading
    2. Dishonest, in that she knew them not to be true
11. On or around 18 June 2018 she submitted a completed licence renewal application online to AAT, wherein she answered "yes" to each of the following questions:
    1. "If you use subcontractors, do you have written arrangements specifying responsibilities,
       supervision and requirements for independence, confidentiality and competence?"
    2. "Are you carrying out customer due diligence on your clients including identifying and
       verifying who your clients are (including beneficial owners where relevant)?"
    3. "Do you retain copies of client identification and verification evidence on file?"
    4. "Do you have appropriate policies or procedures for reporting knowledge or suspicion of
       money laundering?"
    5. "Do you have appropriate policies or procedures for in place for record keeping?"
    6. "Do you have appropriate policies or procedures in place for internal controls?"
    7. "Do you have appropriate policies or procedures in place to risk assess a client?"
    8. "Do you have a quality control process to ensure all principals and staff are complying with your firm's money laundering policies and procedures?"
    9. "I provide letters of engagement to all clients"
    10. "I deliver my services in compliance with the Provision of Services Regulations"
12. Her answers to the questions set out in paragraph 11 above were:
    1. Misleading
    2. Dishonest, in that she knew them not to be true
13. Between 17 December 2018 and 25 March 2019, she failed to deal in an open and cooperative
    manner with AAT in respect of a proposed action plan arising from the Practice Assurance
    Review conduct on 21 August 2018.

The Disciplinary Tribunal considered that Ms Towers’ actions in relation to all allegations amounted to misconduct.

The Tribunal found that Ms Towers had breached AAT’s Code of Professional Ethics and that her
actions were likely to impact public confidence in the Association and bring the Association and the profession into disrepute.

The Disciplinary Tribunal took account of AAT’s submissions on sanction and accepted the advice of
a legal assessor. The Tribunal had regard for the Indicative Sanctions Guidance and referred to the
purpose of imposing a sanction, which is to protect the public, maintain confidence in the profession and ensure high standards of professional conduct by members of the Association.

The Tribunal considered the following to be aggravating features:

• Dishonesty
• Lack of insight
• Lack of remorse
• Her conduct through the investigation and the proceedings

The following were considered as mitigating features:

• Previous good character
• Positive testimonials provided by Ms Towers, with the reservations noted above.
• Evidence that Ms Towers had eventually responded to the proposed action plan arising from
  the Practice Assurance Review conducted on 21 August 2018. 

The Tribunal considered the available sanctions in ascending order of severity and considered that
the nature of the misconduct found represented a serious departure from professional standards and honesty and that the allegations were at the most serious end of the scale.
 

Amanda Towers is hereby: 

1. Expelled; the term of the expulsion is indefinite
2. Ordered to pay costs of £10,000.