Disciplinary outcome: Judith Davis

Judith Davis' 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 06 October 2023, she failed to hold clients’ money in full compliance with AAT’s Clients Money Policy
2. For an unknown period up until on or around 21 August 2023, she provided the service Limited Assurance Engagement whilst not approved to do so
3. For an unknown period up until on or around 16 August 2023, she did not comply with her obligations under the Money Laundering Regulations in force while providing accountancy and/or related services on a self-employed basis. Specifically, she failed to:  
   a. carry out an adequate firm-wide risk assessment; and or 
   b. carry out regular review of her firm’s AML controls and procedures; and/or
   c. perform and/or document ongoing client due diligence for existing clients.

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

Judith Davis is hereby:

1. Reprimanded for a period of two years
2. Fined £1,500
3. Warned about her future conduct.

Consent