Disciplinary outcome: John Gay

John Gay’s professional or personal conduct, was found to be in breach of the Code of Professional Ethics and to have posed a risk to the public or was likely to undermine public confidence in the Association or its members; namely:
1. He failed to comply with his obligations under the relevant Money Laundering Regulations while providing accountancy services to the public, specifically:
1.1 For an unknown period up until on or around 17 February 2023, he failed to carry out an adequate risk assessment and ongoing monitoring in respect of one or more clients and/or
1.2 For an unknown period up until on or around 17 February 2023, he failed to carry out any or any adequate ID procedures in respect of one or more clients and/or
1.3 For an unknown period up until on or around 17 February 2023, he failed to carry out any or any adequate firm-wide money laundering risk assessment and/or
1.4 For an unknown period up until on or around 17 February 2023, he failed to have in place any or any adequate documented AML policies, controls, and procedures and/or
1.5 For an unknown period up until on or around 17 February 2023, he failed to carry out any or any adequate periodic review of his Anti-Money Laundering policies, procedures, and controls.
1.6 For an unknown period up until on or around 17 February 2023, he failed to have undertaken any or any adequate Anti-Money Laundering training for himself and/or

2. For an unknown period up until on or around 17 February 2023, he failed to hold clients’ money in full compliance with AAT’s Clients Money Policy and/or
3. For an unknown period up until on or around 17 February 2023, he failed to have in place any or any adequate Letters of Engagement.

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

John Gay is hereby: 
i. Severely Reprimanded for a period of two years (24 years)
ii. Fined £2000

Consent