Disciplinary outcome: Lee Carmichael

1. He failed to have in place adequate Anti-Money Laundering policies, procedures, and controls.
2. He failed to carry out and/or document any or any adequate periodic review of his Anti-Money Laundering policies, procedures, and controls.
3. He failed to have in place adequate Anti-Money Laundering training for staff members and/or sub-contractors.
4. He failed to carry out adequate client due diligence in respect of one or more clients.
5. He failed to carry out and/or document an adequate risk assessment and/or ongoing monitoring in respect of one or more clients.
6. He provided Limited Assurance Engagement services without being licensed by AAT to do so.

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

The Investigation Team orders that Lee Carmichael be:

1. Fined £2,500.00
2. Severely reprimanded for a period of two years.