Disciplinary outcome: Richard Sanders

1. He failed to comply with his obligations under the relevant Money Laundering Regulations while providing accountancy services to the public, specifically:
   1. From an unknown date until on or around 08 March 2022, he failed to have in place adequate Anti-Money Laundering policies, procedures and controls; and/or
   2. From an unknown date until on or around 08 March 2022, he failed to carry out any or any adequate periodic review of his Anti-Money Laundering policies, procedures and controls
   3. From an unknown date until on or around 08 March 2022, he did not apply and/or record adequate client due diligence measures in respect of one or more clients; and/or
   4. From an unknown date until on or around 08 March 2022, he failed to carry out and/or record ongoing monitoring in respect of one or more clients; and/or
   5. From an unknown date until on or around 08 March 2022, he failed to carry out an adequate firm-wide money laundering risk assessment; and/or
   6. From an unknown period up until on or around 08 March 2022, he failed to have in place adequate Anti-Money Laundering training for staff members and/or sub-contractors.
2. From an unknown date until on or around 08 March 2022, he failed to issue and – or any adequate – letters of engagement to one or more clients, in contravention of AAT’s Client Care policy.
3. From an unknown date until on or around 08 March 2022, he failed to receive and hold clients’ money in accordance with AAT’s Clients’ Money policy.
4. From an unknown date until on or around 08 March 2022, he provided trust and/or company services to the public without being licensed by AAT or registered with HMRC to do so.

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

Richard Sanders is hereby:

1. Reprimanded, with the reprimand to remain live on his record for a period of two years/24 months.
2. Fined £2,500.00
3. Removed from AAT fellow membership (FMAAT) for a period of two years/24 months.

Consent