Disciplinary outcome: Caroline Morcom

Caroline Morcom'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 04 June 2024, she did not comply with her obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis. Specifically, she failed to:
   a. have in place any or any adequate anti-money laundering (AML) policies or procedures; and/or
   b. conduct a regular compliance review of her AML policies, controls, and procedures; and/or
   c. conduct a risk-based assessment as part of initial client due diligence (CDD); and/or
   d. document ongoing CDD for existing clients; and/or
   e. undertake effective anti-money laundering training; and/or
   f. effectively verify the identity of one or more clients.
2. For an unknown period up until on or around 04 June 2024, she failed to hold professional indemnity insurance in compliance with paragraph 4(a) and/or paragraph 4(c) of AAT’s Professional Indemnity Insurance Policy.
3. On or around 22 March 2024, she submitted a licence renewal application wherein she answered “Yes” to the statement “I am complying with my obligations under the Money Laundering Regulations in force and will comply with any other anti-money laundering legislation (as it comes into force) in the exercise of providing accountancy services as an external accountant”.
4. On or around 15 May 2023, she submitted a licence renewal application wherein she answered “Yes” to the statement “I am complying with my obligations under the Money Laundering Regulations in force and will comply with any other anti-money laundering legislation (as it comes into force) in the exercise of providing accountancy services as an external accountant”.
5. Her conduct at Allegation 3 and/or Allegation 4 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.

Caroline Morcom is hereby:

1. Expelled from membership of AAT for a period of three years 
2. Fined £4,000
3. Warned about her future conduct.

Consent