Disciplinary outcome: Howard Haworth

Howard Haworth'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 28 February 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. apply to AAT for approval of a beneficial owner, officer, or manager for H&F Accountants Limited; and/or 
   b. document any or any adequate firm-wide risk assessment; and/or
   c. have in place any or any adequate documented anti-money laundering (AML) policies or procedures; and/or 
   d. conduct a regular compliance review of his firm’s AML policies, controls, and procedures; and/or
   e. undertake any or any effective AML training; and/or 
   f. implement effective client identification and verification procedures in every instance. 
2. On 28 February 2024, he failed to demonstrate that he undertakes relevant continuing professional development in all the areas he is licensed to offer services. 
3. For an unknown period up until or around 28 February 2024, he failed to have a written continuity of practice agreement in place as is required under AAT’s Continuity of Practice Policy. 
4. On dates unknown up to 07 May 2024, he provided Independent Examination and Limited Assurance Engagement whilst not licensed to do so.
5. On or around 09 February 2024, 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 am aware of and will adhere to the requirements of AAT’s Continuity of Practice Policy”
   c. “I will comply with AAT’s CPD Policy and will retain CPD records for AAT’s review for a period of at least five years. If I fail to comply or demonstrate such compliance when requested to do so, I understand this may lead to the removal of my membership from the Register”.
6. His conduct at Allegation 5 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.

Howard Haworth is hereby:

1. Reprimanded for a period of two years
2. Fined £4,000
3. Deemed unfit to hold fellow membership status for a period of two years
4. Warned about his future conduct.

Consent