Disciplinary outcome: Jennifer Richardson

Jennifer Richardson:

1. 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. document any or any adequate firm-wide risk assessment; and/or
   b. conduct a regular compliance review of her firm’s anti-money laundering policies, controls, and procedures; and/or
   c. comply with the registration requirements relating to trust or company service providers
2. Failed to demonstrate that she maintained a record of her continuing professional development (CPD) activities as is required under AAT’s CPD Policy
3. Failed to issue letters of engagement to one or more clients that were fully compliant with paragraph 5 AAT’s Client Care Policy
4. Provided Internal Audit whilst not licensed to do so
5. Acted as a trust or company service provider whilst not licensed to do so
6. Provided self-employed accountancy or related services to the public whilst not licensed or approved to provide such services whilst subject to an exemption
7. Provided self-employed accountancy or related services to the public without being registered with a supervisory authority within the meaning of The Money Laundering Regulations.

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

The Investigations Team orders that Jennifer Richardson be:

1. Severely reprimanded for a period of three years 
2. Fined £5,000
3. Divested of her fellow member status for a period of three years 
4. Warned about her future conduct.