Disciplinary outcome: Nenia Gartland

Nenia Gartland'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. She failed to comply with her obligations under the relevant Money Laundering Regulations while providing accountancy services to the public, specifically:
   • From an unknown period up until on or around 23 May 2023, she failed to carry out any or any adequate initial risk assessments and ongoing monitoring of risk in respect of one or more clients and/or
   • From an unknown period up until on or around 23 May 2023, she failed to carry out any or any adequate periodic review of her Anti-Money Laundering policies, procedures, and controls.
2. From an unknown period up until on or around 23 May 2023, she provided Independent Examinations to one or more clients without being appropriately licensed by AAT to do so.
3. From an unknown period up until on or around 23 May 2023, she failed to have in place any or any adequate Professional Indemnity Insurance coverage, in accordance with AAT’s Professional Indemnity Insurance Policy.
4. From an unknown period up until on or around 23 May 2023, she failed to have in place bank letter acknowledging trust status in accordance with regulation 11 of AAT’s Clients’ Money policy.
5. From an unknown period up until on or around 23 May 2023, she failed to hold clients’ money in a client money account in accordance with regulation 10 of the AAT’s Clients’ Money Policy.
6. From an unknown period up until on or around 23 May 2023, she failed to have in place any or adequate arrangements for Continuity of Practice.

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

Nenia Gartland is hereby:

• Fined £3,500.00
• Severely Reprimanded for a period of two years (24 months)
• Divested of FMAAT status for a period of two years (24 months)
   

Consent