Disciplinary outcome: Paul Billing
Order by consent
In the matter of
Mr Paul Billing FMAAT
Membership number
7814942
Date
15 February 2023
Misconduct
Paul Billing’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 Money Laundering Regulation in force while providing accountancy and/or bookkeeping services to the public, specifically:
1.1. Between an unknown date to on and around 05 October 2021, whilst a full member of AAT, he failed to apply adequate risk-based due diligence and ongoing monitoring measures in respect of one or more clients.
1.2. Between an unknown date to on and around 05 October 2021, whilst a full member of AAT, he failed to undertake an adequate review of his anti-money laundering policies, controls and procedures.
1.3. Between an unknown date to on and around 05 October 2021, whilst a full member of AAT, he did not carry out and/or record an adequate firm-wide money laundering risk assessment.
2. Between an unknown date to on and around 05 October 2021, whilst a full member of AAT, he did not open a clients’ money account, in accordance with regulation 10 of AAT’s Clients’ Money policy.
3. Between an unknown date to on and around 05 October 2021, whilst a full member of AAT, he failed to have in place any or any adequate continuity of practice agreement, in accordance with AAT’s Continuity of Practice policy.
4. Between an unknown date to on and around 05 October 2021, whilst a full member of AAT, he failed to issue any or any adequate letters of engagement to one or more clients, in accordance with AAT’s Client Care policy.
Finding
Grounds for disciplinary action existed and the matter was suitable for exercise of the Investigations team's powers under the Disciplinary Regulations.
Order
Paul Billing is hereby:
i. Fined £3,000.
ii. Severe Reprimand: To remain on Mr Billings record for a period of 2 years.
iii. Divested of his fellow membership (FMAAT) status for a period of 2 years
Consent
Paul Billing has agreed to submit to the decision of the Investigations Team in accordance with Regulation 6 of the Disciplinary Regulations.
