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Guidance on Sanctions and fixed penalty process

The Guidance on Sanctions is used by regulatory committees, the Investigation Committee, disciplinary tribunals of the Disciplinary Committee and the Appeals Panel of the Appeal Committee for all complaints they consider against ICAEW members (current and former), students, affiliates and member / regulated / contracted firms. This page outlines the updates and access to the Guidance on Sanctions and information on the fixed penalty process.

Guidance on Sanctions

The current version of the Guidance on Sanctions is effective from 1 July 2019. This version includes the introduction of revised sanctions for AML breaches which aim to deter money laundering by ICAEW supervised firms. The changes include:

  • sanctions relating to a firm’s failure to have AML policies and procedures or to implement them now have a starting point calculated as £3,000/£2,000 per principal (minimum of Categories C and D) and capped maximum fine for the largest firms. The starting point can be increased or decreased by the relevant professional standards committees and tribunals depending on the presence of aggravating and mitigating factors;
  • the introduction of further specific sanctions for identifiable standalone breaches of the Money Laundering Regulations in relation to firms and individuals; and
  • a dedicated chapter for AML sanctions to indicate the seriousness with which these failures are treated by ICAEW.

Fixed penalty process for minor complaints 

The fixed penalty process enables certain types of lower level, compliance-type complaints to be dealt with by way of fixed penalty. The process only applies to complaints which the ICAEW Regulatory Board determines suitable for the process and where the complaint(s) and proposed penalty are agreed by respondents / respondent firms. The new process avoids the need for less serious complaints to considered by the Investigation Committee and therefore matters are dealt with more efficiently.