AAT's Reprimand - Our Response
AAT published a disciplinary outcome dated 25 March 2026 concerning Timothy Emmony, the AAT licence holder for Gilroy Finance Group and the businesses named in the decision. The outcome records four regulatory matters, a £2,500 fine and a severe reprimand.
The published notice records the formal findings, but it does not explain the limited circumstances behind them, whether clients were affected or what action was taken. We are therefore publishing this explanation so that clients and other interested parties can understand the complete context.
As the AAT licence holder, Tim is the individual formally named in the outcome. However, the Quality Assurance visit examined activities undertaken through the wider group, which has four partners and 40 members of staff.
Background
AAT is a well known and well respected professional body. We respect its role, uphold its standards and accept the findings that were made. What we believe is missing from the published notice is the context and mitigation discussed during the process.
During and after the Quality Assurance visit, we engaged openly and cooperatively with AAT and were given the opportunity to present mitigation. The final report included that context and, on balance, we accepted the outcome rather than appeal it and proceed to further hearings.
We did not, however, appreciate how little of that context would appear in the published notice. We have therefore decided to explain the circumstances openly because our clients and fellow professionals deserve to understand what happened, whether anyone was affected and what we have done in response.
Introduction to our response
It might seem strange for an accountant to be so open about a regulatory outcome, but we believe transparency matters. Although AAT’s notice records the formal findings, it does not explain the limited circumstances behind them. Without that context, readers could reasonably assume that the issues were widespread or that the quality of our work and advice was affected. That was not the case.
We are proud to employ 40 people across six offices. Through more than a dozen acquisitions, we have brought together firms operating under different professional bodies, licensing arrangements, systems and procedures. A significant part of that work has involved strengthening and standardising policies and controls across the group.
This response is not intended to undermine AAT’s role or avoid responsibility for the matters identified. It explains what happened, the effect on clients, the mitigating circumstances and the action we took.
The most important points
Before explaining the four findings individually, it is important to record the wider outcome of the review:
- No client suffered loss, financial or otherwise.
- No concern was raised about the quality of our accountancy or tax work, or the advice provided to clients.
- No concern was raised about our understanding of tax or financial reporting standards.
- No concern was raised about technical competence, staff qualifications, training or CPD.
- No concern was raised about the activities of any client.
- Each finding related to one identified instance - not multiple or widespread instances.
- Each matter was corrected or addressed.
The Quality Assurance Visit
We were first notified about the Quality Assurance visit in mid 2024, and it took place in March 2025. We prepared thoroughly for the visit and made the relevant records, systems and information available to the reviewer.
The reviewer completed the scheduled checks within the one day visit. At its conclusion, we understood that the firm had performed as expected and were given a schedule of follow up actions and information to provide. We engaged openly and cooperatively throughout.
Approximately a year later, we were informed that four of the matters identified during the visit were considered sufficiently serious for AAT to investigate as potential disciplinary matters. Each issue was addressed or corrected immediately where appropriate, and we provided the relevant context and mitigating information.
The penalties were at the lowest level for each finding and, in some instances, below the suggested minimum fine. AAT also acknowledged that the penalties could have been higher but were reduced because of the limited effect on clients.
Our concern is not that shortcomings were identified. It is that the published outcome presents each finding in isolation, without the context supplied during the process or the broader results of the review.
In our experience of auditing, an identified shortcoming is normally considered within the findings of the report as a whole. An administrative oversight would not ordinarily be presented without also recognising where a business was otherwise operating effectively. We believe that, somewhere between the reviewer’s visit and the publication of the disciplinary outcome, that wider picture and the mitigating context behind each finding were lost.
Misconduct 1
“He provided services as an external accountant in the United Kingdom via one or more firms without being registered with one of the supervisory authorities listed in Schedule 1 of the Money Laundering Regulations 2017.”
Adverse impact on our clients: None identified
Monetary loss to our clients: £0
Fine received: £1,000
Our response
We did not tell AAT about one newly acquired company, which is a wholly owned subsidiary of the group. AAT supervises firms for anti-money laundering purposes and, although the company’s parent (our ultimate holding company) was registered, this particular subsidiary had not been added separately.
We have completed more than a dozen acquisitions, all of which have been supervised apart from this one omission. It resulted from a last minute change to the corporate structure used when we acquired the firm, rather than any intention to leave the company unsupervised. The company operated using the same policies, procedures and back-office systems as the rest of the group.
The omission came to light because we openly discussed the company during the Quality Assurance visit. Once it was identified, we added the company to AAT supervision before the reviewer had left our office. We accept the importance of registering every relevant entity and have taken steps to ensure this is addressed during all future acquisitions.
Misconduct 2:
“He failed to carry out any – or any adequate – client due diligence in respect of one or more clients in contravention of Regulations 27 and 28 of the Money Laundering Regulations 2017.”
Adverse impact on our clients: None identified
Monetary loss to our clients: £0
Fine received: £1,500 (combined fine for misconduct 2 and 4)
Our response
The identification documents for a newly added minority shareholder of a limited company client were not immediately available through the new anti money laundering software we were implementing at the time of the review.
The individual had recently been added by the client and only appeared when we resynchronised the system with Companies House in front of the reviewer. We had not previously been notified of the change. It is common for clients to arrange share changes through solicitors without immediately informing their accountant, which was one of the reasons we were moving to a system capable of synchronising this information directly.
We were open with the reviewer about the migration of our AML records and the work being undertaken to reflect recent changes to AAT guidance. We offered to demonstrate the process using another client file, but no additional file was reviewed. Had we been instructed to undertake the share transfer ourselves, our normal procedures would have required the relevant documentation to be obtained at that point.
This was caused by a delay in the shareholder change being identified and was not representative of the firm’s wider client due diligence procedures. Once the change was identified, the required identification documents were obtained. We have since worked with the software provider to increase the frequency of Companies House synchronisations and reduce the risk of a similar delay occurring again.
Misconduct 3:
“He received and/or held clients’ money in his firm’s office account in contravention of Paragraph 10 of AAT’s Clients’ Money Policy.”
Adverse impact on our clients: None identified
Monetary loss to our clients: £0
Fine received: £0 (Reduced from £500 due to mitigating factors)
Our response
Several years ago, we made a deliberate decision not to hold client money. This followed an acquisition where clients’ tax refunds had routinely been paid into the firm’s business account before being passed to the clients, less any accountancy fees. We were uncomfortable with that arrangement and believed clients should receive their refunds directly.
The finding concerned one client acquired as part of another firm. The client elected to use our bank details to reclaim the refund because their own bank account was due to close. When the refund arrived (we cannot be specific about the amount, but it was not far off the equivalent of an hour’s pay at minimum wage) we contacted the client immediately and offered to return it. The client declined and asked us to leave the amount on their account as credit against a future invoice, which we did.
We’re deeply upset by this finding because holding client money was a practice we had actively tried to avoid. Nevertheless, we recognise that the amount was held in our office account and have updated our policies and controls so that any similar situation can be handled correctly in future.
Misconduct 4:
“He provided Limited Assurance Engagement services to one or more clients without being appropriately licensed by AAT to do so in contravention of Regulation 6.4 of AAT’s Licensing Regulations.”
Adverse impact on our clients: None identified
Monetary loss to our clients: £0
Fine received: Included in the £1,500 combined fine for Misconducts 2 and 4
Our response
We completed accountants’ certificates without realising that AAT treated this as a separate Limited Assurance Engagement service that needed to be specifically added to our licence.
Accountants’ certificates are a routine service commonly provided by qualified accountants, usually in connection with borrowing or mortgage applications. Within our business, they are always completed by a partner. We did not realise that AAT required this particular service to be listed separately on our licence.
Once the requirement was explained to us, we immediately asked AAT to add the service to our licence. AAT made the change without any further enquiry or issue. No certificates were reviewed during the Quality Assurance visit, no concerns were raised about the quality of this work or the qualifications of the people completing it.
This was an administrative licensing oversight, rather than a shortcoming in our ability to perform the work, and it was corrected as soon as it was identified.
A final word
The four findings arose from specific circumstances identified during the Quality Assurance review. No client suffered loss, financial or otherwise, no concerns were raised about the quality of our work or advice, and every matter was corrected or addressed.
We recognise the importance of regulatory compliance and have strengthened our processes in response.
Anyone with any questions or concerns is welcome to contact us directly.