Disciplinary outcome: David Morgan

David Morgan'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 24 October 2023, 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. perform and document a comprehensive firm-wide risk assessment; and/or
   b. document AML training undertaken; and/or
   c. implement effective client identification and verification procedures in all instances.
2. On 24 October 2023, he did not demonstrate full compliance of AAT’s Continuing Professional Development (CPD) Policy. Specifically, he failed to demonstrate that he: 
   a. remained competent to conduct work in the areas of charities and independent examinations; and/or
   b. regularly reviewed his CPD needs in the areas he is licensed to offer services; and/or
   c. adequately documented his CPD activities. 
3. For an unknown period up until on or around 24 April 2024, he failed to have in place a continuity agreement that fully complied with AAT’s Continuity of Practice Policy. 
4. On or around 29 June 2023, he submitted a licence renewal application wherein he answered “Yes” to the statement, “I am aware of and will adhere to the requirements of AAT’s Continuity of Practice Policy.
5. His conduct at Allegation 4 above was misleading. 

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

David Morgan is hereby:

1. Reprimanded for a period of three years
2. Fined £2,000
3. Warned about his future conduct.

Consent