Disciplinary outcome: Sanjay Ravatia

Sanjay Ravatia’s conduct was found to be in breach of the Code of Professional Ethics and to have posed a risk to the public and/or undermine public confidence in the Association and its members as follows:

1. For an unknown period up until on or around 18 January 2024, 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. have in place any or any adequate procedures to report discrepancies to Companies House concerning persons of significant control in connection to limited company clients and/or limited liability partnership clients; and/or
   b. perform and document a firm-wide risk assessment; and/or
   c. have in place any or any adequate anti-money laundering (AML) policies or procedures; and/or 
   d. conduct a regular compliance review of his firm’s AML policies, controls, and procedures; and/or
   e. conduct a risk-based assessment as part of initial client due diligence (CDD); and/or
   f. document ongoing CDD for existing clients; and/or
   g. undertake any or any effective AML training.
2. For an unknown period up until on or around 23 November 2023, he provided Trust and Company Secretarial Services, and Corporation Tax without being licensed by AAT to do so.
3. For an unknown period up until on or around 12 January 2023, he failed to have in place any and/or any adequate continuity of practice agreement.
4. For an unknown period up until on or around 12 January 2023, he failed to have in place any process in place for handling client complaints as is required under AAT’s Client Care Policy.
5. On dates unknown, he failed to issue letters of engagement that were fully compliant with AAT’s Client Care Policy.
6. On dates unknown, he failed to comply with AAT’s Clients’ Money Policy in that clients’ money totalling £4,532.71 was received into his firm’s office bank account.
    

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

Sanjay Ravatia is hereby:

1. Severely reprimanded for a period of two years 
2. Fined £4,500 
3. Deemed unfit to hold fellow membership status for a period of two years
4. Warned about his future conduct. 

Consent