Mr Sa’id, a sole practitioner had, during the course of conducting anti-money laundering checks required by the rules operative at the material time, failed to identify a person related to his client as a Politically Exposed Person (“PEP”). Had he made this discovery he would have been obliged to go on to carry out Enhanced Due Diligence (“EDD”).

Mr Sa’id accepted his failure but denied that this brought him within the ambit of professional misconduct as alleged by the Applicant.

The Tribunal did not find the relevant Principles or failure to achieve Outcome 7.5, as set out in the allegations, proved to the required standard i.e., the balance of probabilities and it therefore dismissed the allegations.