Disciplinary outcome: Lynette Behegan

Lynette Behegan was found to have committed an act or omission that falls short of the standards reasonably expected of her, including but not limited to those matters listed in the Code of Professional Ethics, which brings, or is likely to bring, discredit to her, the accountancy profession or AAT; namely:

1. For an unknown period up until on or around 14 February 2023 she failed to have in place adequate Anti-Money Laundering policies, procedures, and controls.
2. For an unknown period up until on or around 14 February 2023 she failed to carry out adequate client due diligence in respect of one or more clients
3. For an unknown period up until on or around 14 February 2023 she failed to carry out an adequate risk assessment and ongoing monitoring in respect of one or more clients.
4. For an unknown period up until on or around 14 February 2023 she failed to carry out an adequate firm-wide money laundering risk assessment.
5. For an unknown period up until on or around 14 February 2023 she failed to carry out any or any adequate periodic review of her Anti-Money Laundering policies, procedures, and controls.
6. For an unknown period up until on or around 14 February 2023 she failed to have in place adequate Anti-Money Laundering training for staff members and/or sub-contractors.

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

Lynette Behegan is hereby:

1. Fined £5,000.00
2. Severely Reprimanded, with the severe reprimand to remain live on her record for a period of three years (36 months).

Consent