Disciplinary Update 2026, Issue 3

Included within the latest published orders are the following:

Tribunals Committee tribunal order

• Criminal conviction
  A tribunal excluded a member following criminal convictions for drugs related offences.

Tribunals Committee settlement orders

• Dishonesty
  A member did not make adequate enquiries and / or provided incorrect advice to ‘A’ which resulted in an underpayment of tax and was also found to have provided false or misleading information to HMRC.

• Breaches of the Insolvency Regulations
  An ICAEW-licensed insolvency practitioner failed to distribute dividends, included an incorrect statement in a report to creditors, failed to ensure the Statement of Affairs of two proposed creditors’ voluntary liquidations complied with the requirements of Rule 6.4 of the Insolvency (England & Wales) Rules 2016, failed to take reasonable care in their handling of employee claims and/or dealings with the Redundancy Payments Service.

• Professional behaviour matter
  A member transferred data which was the property of their employer to their personal email address without authorisation.

• Audit failings
  A member failed to obtain sufficient appropriate audit evidence in respect of various account balances for a number of clients over several years.

• Breaches of ICAEW Clients’ Money Regulations
  A member breached various regulations of the ICAEW Clients’ Money Regulations, including withdrawing amounts from the client bank account that were greater than the credit balance held for that client and processing transactions through the clients’ money bank account when the transactions did not relate to accountancy services being provided.

Conduct Committee consent orders

• Failure to cooperate
  A member failed to provide the information, documents and explanations requested by ICAEW.

• Regulatory breaches
  Failure to notify ICAEW of a firm’s formation within the required time period, failure to ensure their firm was supervised by an appropriate anti-money laundering supervisory authority, and engaging in public practice through their firm without any professional indemnity insurance.

• Audit failings
  A firm failed to obtain sufficient appropriate audit evidence and failed to prepare sufficient audit documentation in respect of provisions for two entities.

• Breaches of Money Laundering Regulations

  A firm failed to comply with the Money Laundering Regulations in respect of two clients, including the failure to have effective policies and procedures in place sufficient to achieve internal reporting of information received by the firm, which could give rise to reasonable grounds for suspecting that another person was engaged in money laundering, to the firm’s nominated officer to determine whether further disclosure should be made, and the failure to carry out appropriate ongoing monitoring of the business, including scrutiny of transactions and source of funds.

  AND

  Another firm failed to comply with the Money Laundering Regulations as they did not establish and maintain appropriate and risk-sensitive policies and procedures relating to customer due diligence measures and ongoing monitoring and risk assessment and management.

• Carrying out regulated activities without authorisation
  A firm carried out regulated insurance activities without appropriate authorisation, contrary to the terms of its Designated Professional Body Investment Business Licence.

• Breaches of Client Money Regulations

  A firm failed to comply with the Clients’ Money Regulations, including not withdrawing client money from the client bank account as soon as it cleared.

  AND

  Another firm failed to comply with the Clients’ Money Regulations, including not withdrawing client money from the client bank account as soon as it cleared.

  AND

  Another firm failed to comply with the Clients’ Money Regulations, including not withdrawing client money from the client bank account as soon as it cleared.

• Audit regulatory breaches
  A firm signed audit reports when ineligible and failed to notify ICAEW of changes affecting its audit registration.

Conduct Committee fixed penalty orders

• Criminal conviction
  A member was convicted of a Road Traffic Offence.

• Regulatory breaches
  A member failed to notify ICAEW of a firm’s formation within the required timeframe, failed to ensure their firm was supervised by an appropriate anti-money laundering supervisory authority, and engaged in public practice through their firm without ICAEW compliant professional indemnity insurance.

• AML supervision failure
  A member failed to ensure their firm was supervised by an appropriate anti-money laundering supervisory authority.

Key themes

• Audit quality and assurance failings
• Anti-money laundering compliance
• Clients’ money breaches
• Regulatory co-operation and notification failures
• Criminal convictions

Useful links

Please make use of the following resources to ensure you are up to date with the latest regulatory information and news.

• Clients’ Money Regulations
• Check and monitor your firm’s audit eligibility
• Anti-money laundering resources
• Duty to cooperate with investigations: responding promptly and professionally
• ICAEW Code of Ethics
• ICAEW’s Regulation hub
• Disciplinary Bye-laws

Further details can be found on our Disciplinary Database or please visit our Public Hearings page.