Disciplinary outcome: Raymond Gardener
Order by consent
In the matter of
Mr Raymond Gardener MAAT
Membership number
188810
Date
13 September 2023
Misconduct
Raymond Gardener’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. From an unknown date until on or around 22 September 2022, whilst a full member of AAT, Raymond Gardener failed to apply adequate risk-based due diligence and ongoing monitoring measures in respect of one or more clients.
2. From an unknown date until on or around 22 September 2022, whilst a full member of AAT, Raymond Gardener failed to not carry out and/or record an adequate firm-wide money laundering risk assessment.
3. From an unknown date until on or around 22 September 2022, whilst a full member of AAT, Raymond Gardener did not maintain an adequate written record of his Anti-Money laundering policies, controls and procedures.
4. From an unknown date until on or around 22 September 2022, whilst a full member of AAT, Raymond Gardener, did not carry out an adequate review of his Anti-Money laundering policies, controls and procedures.
5. From an unknown date until on or around 22 September 2022, whilst a full member of AAT, Raymond Gardener, did not have adequate Anti-Money laundering training in place for his relevant employees in accordance with MLR 2017.
6. From an unknown date until on or around 22 September 2022, whilst a full member of AAT, Raymond Gardener failed to issue any or any adequate letters of engagement to one or more clients, in accordance with AAT’s Client Care policy.
7. From an unknown date until on or around 22 September 2022, whilst a full member of AAT, Raymond Gardener did not open a clients’ money account, in accordance with regulation 10 of AAT’s Clients’ Money 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
Raymond Gardener is hereby:
i. Fined £500
ii. Severe Reprimand, to remain on Mr Gardener’s record for a period of two years.
Consent
Raymond Gardener has agreed to submit to the decision of the Investigations Team in accordance with Regulation 6 of the Disciplinary Regulations.
