Disciplinary outcome: Tarin Smillie

1. She failed to carry out any or any adequate risk assessment and ongoing monitoring in respect of one or more clients.
2. She failed to carry out any or any adequate client due diligence in respect of one or more clients.
3. She provided services as a Trust or Company Service Provider (TCSP) to one or more clients:
   3.1 Without being appropriately licensed by AAT to do so; and
   3.2 Without being appropriately registered with HMRC as required under the relevant Money Laundering Regulations.
4. She provided Limited Assurance services to one or more clients without being appropriately licensed by AAT to do so.
5. She failed to have in place any or any adequate professional indemnity insurance coverage, in accordance with AAT’s Professional Indemnity Insurance Policy.

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

Tarin Smillie is hereby:

1. Reprimanded for a period of two years
2. Fined £2,000

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.