Disciplinary outcome: Colette Spence

Colette Spence'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 09 February 2022, she failed to carry out an adequate firm-wide money laundering risk assessment.
2.For an unknown period up until on or around 09 February 2022, she failed to apply adequate risk-based due diligence and ongoing monitoring measures in respect of one or more clients. 
3.For an unknown period up until on or around 09 February 2022 she failed to have in place adequate Anti-Money Laundering policies, procedures and controls
4.For an unknown period up until on or around 09 February 2022 she failed to have in place adequate Anti-Money Laundering training for staff members and/or sub-contractors.
5.For an unknown period up until on or around 09 February 2022 she failed to adequately screen one or more ‘relevant employees’ before they start working for her firm.
6.For an unknown period up until on or around 09 February 2022, she failed to have sufficient PII cover.
7.For an unknown period up until on or around 09 February 2022, she failed to comply with Regulation 10 of the Clients’ Money Policy as, she paid client’s money, totalling around £34,336.19 of client’s tax refunds into the firm’s office savings account. 

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

Colette Spence is hereby:

1. Severely Reprimanded; the reprimand will expire 36 months from the date of this Order. 
2. Fined £3000.
3. Divested of fellow membership (FMAAT) status for 36 months.

Consent