Disciplinary outcome: Nigel Johnson

1. He did not comply with his obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis. Specifically, he failed to:
   a. conduct a regular compliance review of his firm’s anti-money laundering (AML) policies, controls, and procedures; and/or
   b. document AML risk assessments for new and existing clients; and/or
   c. document ongoing client due diligence for one or more existing clients; and/or
   d. implement effective client verification procedures in every instance.
2. He failed to hold clients’ money in full compliance with paragraph 11, paragraph 33(b) and paragraph 39 of AAT’s Clients’ Money Policy
3. He failed to maintain an adequate record of continuing professional development (CPD) activities undertaken as is required under AAT’s CPD Policy
4. He failed to maintain the minimum level of professional indemnity insurance (PII) cover as set out in paragraph 5 of AAT’s PII Policy
5. He submitted a licence renewal application wherein he answered “Yes” to the following statements:
   a. “I am complying with my obligations under the Money Laundering Regulations in force and will comply with any anti-money laundering legislation (as it comes into force) in the exercise of providing accountancy services as an external accountant”
   b. “I will comply with AAT’s CPD Policy and will retain my CPD records for AAT’s review for a period of at least five years”
   c. “I understand that all clients' money must be held in a client bank account and if I do hold clients' money, I will comply with my obligations under AAT's Clients' Money Policy”.
6. His conduct at Allegation 5 above was misleading.

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

Nigel Johnson is hereby:

1. Reprimanded for a period of two years
2. Fined £4,000
3. Deemed ineligible to hold fellow member (FMAAT) status for a period of two years
4. Warned about his future conduct.

The decision of the Investigations Team shall stand as an Order of the Association pursuant to Regulations 5.2 and 5.3 of the Disciplinary Regulations.