Hearings, orders, and decisions

Name of Respondent:	Mr Ravi Kanani, 069297/MATT
Complaint	The allegation is that Mr Ravi Kanani is liable to disciplinary action under Disciplinary Bye-law 4.1a
Date of hearing:	6 May 2025
Time:	10:00
Place:	Remote hearing – please contact ife.thomas@icaew.com for details

 

Name of Respondent:	Dr Mahendra Maganlal Pattni FCA, 057863/MATT
Complaint	The allegations are that Mr Mahendra Maganal Pattni is liable to disciplinary action under Disciplinary Bye-law 4.1b
Date of hearing:	17 April 2025
Time:	10:00
Place:	Remote hearing – please contact vanessa.broxham@icaew.com for more details

 

Name of Respondent:	Mr Graham Michael Wildin FCA, 038856/MATT
Allegation:	The allegation is that Mr Graham Michael Wildin is liable to disciplinary action under Disciplinary Bye-law 4.1a
Date of hearing:	26 and 27 March 2025
Time:	10:00
Place:	IDRC, 1 Paternoster Lane, St Paul’s, London, EC4M 7BQ

 

Name of Respondent:	Ms Janet Elizabeth Parker FCA, 062184/MATT
Allegation:	The Allegation is that Ms Janet Elizabeth Parker FCA is liable to disciplinary action under Disciplinary Bye-law 4.1a
Date of hearing:	17 March 2025
Time:	10:00
Place:	Remote hearing – please contact diane.waller@icaew.com for details

 

Name of Respondent:	Mr Shivam Amin, 061407/MATT
Allegation:	The complaint is that Mr Shivam Amin is liable to disciplinary action under Disciplinary Bye-law 4.1a
Date of hearing:	27 and 28 February 2025
Time:	10:00
Place:	Remote hearing – please contact diane.waller@icaew.com  for details

 

Name of Respondent:	Mrs Shelagh Brownlow-Clote – 060658/MATT, 061455/MATT and 063812/MATT
Complaint	The allegations are that Mrs Shelagh Brownlow-Clote is liable to disciplinary action under Disciplinary Bye-laws 4.1a and 4.1b.
Date of hearing:	18 February 2025
Time:	10:00
Place:	Remote Hearing – Please contactvanessa.broxham@icaew.comfor details

 

Name of Respondent:	Mr Andrew Dix - 075407/INSR
Complaint	Mr Dix is applying for a review of a decision made by the Insolvency Licensing Committee to restrict his insolvency licence.
Date of hearing:	13 February 2025
Time:	10:00
Place:	Remote Hearing – Please contact diane.waller@icaew.com for details

 

Name of Respondent:	Mr John Henry Peter Upton FCA,  035052/MATT
Allegation:	The allegations are that Mr John Henry Peter Upton FCA is liable to disciplinary action under Disciplinary Bye-law 4.1a and Disciplinary Bye-law 4.1b
Date of hearing:	11, 12 and 13 February 2025
Time:	10:00
Place:	IDRC,1 Paternoster Lane, St Paul’s, London, EC4M 7BQ

 

Name of Respondent:	Mr Chung Wah Tang FCA, 070569/MATT
Allegation:	The complaint is that Mr Chung Wah Tang FCA is liable to disciplinary action under Disciplinary Bye-law 4.1c
Date of hearing:	6 March 2025
Time:	10:00
Place:	Remote hearing – Please contact ife.thomas@icaew.com for details

 

Name of Respondent:	Mr Kamran Khalil FCA, 070895/MATT and 068624/MATT
Allegation:	The allegations are that Mr Kamran Khalil FCA is liable to disciplinary action under Disciplinary Bye-laws 4.1c and Disciplinary Bye-law 4.1a
Date of hearing:	10 and 11 March 2025
Time:	10:00
Place:	Remote hearing – please contact diane.waller@icaew.com  for details

If you think your hearing should be held in private, you must make an application in writing to the Head of Committees and Tribunals. The regulations governing such an application can be found in the Investigation and Disciplinary Regulations.

An application needs to be made within 21 days of service of the documents sent by the Head of Committees and Tribunals further to Regulation 39.2 of the Investigation and Disciplinary Regulations. These are the documents sent once allegations have been referred from the Conduct Committee to the Tribunals Committee.

An application can be made by ICAEW's Conduct Department or by the subject of the formal allegation(s) under regulation 39.1(b) and 39.2(c), as appropriate. If the subject of the formal allegation(s) makes an application under regulation 39.2(c), Conduct Counsel may file a written response to the Head of Committees and Tribunals 7 days before the case management hearing.

The application will be determined by the case management chair at the case management hearing subject to the requirements of the Investigation and Disciplinary Regulations 39.1, 39.2 and 43.1.

Pursuant to regulation 43.2, the case management chair may decide that the press and public shall be excluded from the whole or any part of the final hearing where it appears appropriate to do so in the interests of justice or for any other exceptional reason provided that:

a. the circumstances of the case outweigh the public interest in holding a public hearing; and

b. the case management chair making the decision is satisfied that the parties have had an opportunity to make representations.

The case management chair shall give the parties a summary of reasons for allowing or dismissing any application made under regulation 39.1(b) or 39.2(c). An application can also be made to a panel of the Tribunals Committee at any final hearing, if the applying party can demonstrate that they could not have made the application at the case management hearing, as outlined above.

At the final hearing, you may still ask the Tribunals Committee panel whether it is prepared to proceed in private. This would usually be on the first day of a hearing, but the panel can exercise the power to sit in private at any stage, even if none of the parties have asked it to do so; for example, if it is necessary to protect the identity of a third party. However, we can never guarantee anonymity.

When a panel agrees to hold all or part of the hearing in private, it gives its reasons on the day, and in public, unless such reasons as are given, do not, in the opinion of the panel, unreasonably undermine the purpose of proceeding in private. The panel also gives these reasons in writing if the formal allegations are found proved.

The panel has the power to proceed in private by excluding the press or public from the whole or any part of a hearing, whether or not the parties ask it to do so. It can do this at any stage of a hearing. When it decides whether to exclude anyone, the panel considers:

• the interests of justice
• any other special reason or
• the circumstances of the case

The panel will assess whether these factors outweigh the public interest in holding a public hearing. The panel must also be satisfied that both parties have been given an opportunity to make representations.

This section lists a summary of all recent disciplinary decisions (apart from cases found not proved). All of these decisions can go to an Appeal Committee upon successful application. We do not publish details of cases where the formal allegations are found not proved, or where a decision has been made that the matter should not be published. A full report of decisions is available in the ‘Full reports of disciplinary orders and regulatory decisions’ section below.

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Disciplinary Committee – tribunal summary of decision

Dr David John Oates FCA of Hull, United Kingdom

A tribunal of the Tribunals Committee made the decision recorded below having heard a formal allegation on 4 February 2025.

Type of Member Member

Terms of allegations

Between 26 July 2023 and 12 August 2023, Dr David Oates FCA failed to provide the information, explanations and documents requested by letter dated 26 July 2023, issued in accordance with Investigation and Disciplinary Regulation 16.1. This was contrary to Disciplinary Bye-law 8.

Dr David Oates FCA is therefore liable to disciplinary action under Disciplinary Bye-law 4.1c.

Finding:

Allegation proved by admission

Order:

Severe reprimand
Ancillary order regarding provision of information to ICAEW by 31 March 2025
Pay Costs of £3,840

This decision may be subject to appeal

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Disciplinary Committee – tribunal summary of decision

Mr Daniel Adam West ACA of Ferryhill, United Kingdom

A tribunal of the Tribunals Committee made the decision recorded below having heard a formal allegation on 30 January 2025.

Type of Member Member

Terms of allegations

Allegation 1b

On or around 22 April 2022, Mr Daniel Adam West ACA, in his position as [PRIVATE] for ‘A’ Limited paid for a private expense out of company funds without authorisation.

This was contrary to R115.1 (Professional Behaviour) of ICAEW’s Code of Ethics (effective 1 January 2020).

Mr Daniel Adam West ACA is therefore liable to disciplinary action pursuant to Disciplinary Bye-law 4.1a (effective between 14 October 2019 and 31 May 2023).

Allegation 2a

On or around 22 April 2022, Mr Daniel Adam West ACA posted a purchase invoice entry in Sage on the ‘B’ account, with the invoice reference [PRIVATE] for £600 when no such invoice existed.

Mr Daniel Adam West ACA’s conduct was dishonest because when he posted the entry, he knew that there was no corresponding invoice.

Mr Daniel Adam West ACA is therefore liable to disciplinary action pursuant to Disciplinary Bye-law 4.1a (effective between 14 October 2019 and 31 May 2023).

Allegation 2b

On or around 22 April 2022, Mr Daniel Adam West ACA, posted a purchase invoice entry in Sage on the ‘B’, with the invoice reference [PRIVATE] for £600 when no such invoice existed contrary to R111.1 (Integrity) of ICAEW’s Code of Ethics (effective 1 January 2020).

Mr Daniel Adam West ACA’s conduct lacked integrity because when he posted the entry, he knew that he was entering details of an invoice that did not exist onto his employer’s accounting system.

Mr Daniel Adam West ACA is therefore liable to disciplinary action pursuant to Disciplinary Bye-law 4.1a (effective between 14 October 2019 and 31 May 2023). Mr Daniel Adam West is therefore liable to disciplinary action under Disciplinary Bye-law 4.1a (effective 14 October 2019 to 31 May 2023).

Finding:

Allegations 1(b) and 2(b) proved by admission;
Allegations 2(a) found proved;

Order:

Severe reprimand
Fine £3,000
Costs £10,717

This decision may be subject to appeal

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Disciplinary Committee – tribunal summary of decision

Mr David Lloyd Evans of Newport, United Kingdom

A tribunal of the Tribunals Committee made the decision recorded below having heard the formal allegations on the 15 & 16 January 2025

Type of Member Member

Terms of allegations

Allegation 1

1. Mr David Evans ACA, as principal of ‘The Firm’, failed to fulfil assurances provided to ICAEW following a QAD visit in April 2016, as follows:

b. ‘request ‘The bank’ open a client account for the LLP…expected by 31 July 2016’

At a subsequent QAD visit on 11 April 2019, it was found that these assurances had not been complied with, contrary to Practice Assurance Regulation 4 (effective 1 January 2008).

Mr David Evans ACA is therefore liable to disciplinary action under Disciplinary Bye-law 4.1a (effective from 1 January 2016 to 2 October 2016, 3 October 2016 to 10 October 2017, 11 October 2017 to 14 October 2018, 15 October 2018 to 13 October 2019 and 14 October 2019 to 31 May 2023). 

Allegation 2

2. Between 31 December 2019 and 21 May 2020, Mr David Evans ACA, on behalf of ‘The Firm’ and / or ‘Firm B’, failed to cooperate with the Practice Assurance Committee (PAC) in carrying out its functions under the Practice Assurance Scheme, by not providing the information listed below as requested by the PAC on 19 November 2019:
1. ‘by 31 January 2020, confirmation that it has taken all the actions proposed to address the CMR issues raised by QAD’; and / or
2. ‘documentary evidence that ‘The Firm’ has registered with the ICO by 31 January 2020’

Mr David Evans ACA’s conduct was contrary to Practice Assurance Regulation 12 (effective 1 July 2019).

Mr David Evans ACA is therefore liable to disciplinary action under Disciplinary Bye-law 4.1c (effective between 14 October 2019 and 31 May 2023). 

Allegation 3

3. Between 31 December 2019 and 21 January 2021, Mr David Evans ACA, on behalf of ‘The Firm’ and / or ‘Firm B’, failed to cooperate with the Practice 
   Assurance Committee (PAC) in carrying out its functions under the Practice Assurance Scheme, by not providing the information listed below as requested by the PAC on 19 November 2019:
1. the results of an external CMR compliance review conducted by a training organisation or similar to be submitted to the Committee by no later than 29 February 2020. The reviewer should be asked to comment specifically on how the firm has addressed the issues raised during the review; and / or
2. the results of an external MLR compliance review conducted by a training organisation or similar to be submitted to the committee by no later than 29 
   February 2020. The reviewer should be asked to comment specifically on how the firm has addressed the issues raised during the review.

Mr David Evans ACA’s conduct was contrary to Practice Assurance Regulation 12 (effective 1 July 2019 to 31 May 2023).

Mr David Evans ACA is therefore liable to disciplinary action under Disciplinary Bye-law 4.1c (effective between 14 October 2019 and 31 May 2023)

Allegation 4

4. Between 28 May 2019 and 1 August 2019, Mr David Evans ACA, as principal of ‘The Firm’, failed to fulfil the following assurance provided to ICAEW following a QAD visit in May 2019:

‘The intention is to move the remaining few clients from ‘The Firm’ to ‘Firm B’as soon as possible so only one licence is needed. By 31 July 2019’

Mr David Evans ACA’s conduct was contrary to Practice Assurance Regulation 4 (effective 1 January 2008 to 30 June 2019 and /or Practice Assurance Regulation 8 (effective 1 July 2019).

Mr David Evans ACA is therefore liable to disciplinary action under Disciplinary Bye-law 4.1a (effective from 15 October 2018 to 13 October 2019).

Allegation 5

5. Between 1 May 2020 and 31 May 2023, Mr David Evans ACA failed to cooperate promptly and in full with the investigation of the complaints made against him, in that he failed to substantively respond to any or all of the correspondence from ICAEW’s Professional Conduct Department, as set out in Schedule A below and in breach of Disciplinary Bye-law 10.7 (effective 14 October 2019 to 31 May 2023).

Schedule A

1. Letter dated 1 May 2020
2. Letter dated 6 August 2020
3. Letter dated 8 September 2020
4. Letter dated 23 September 2020
5. Letter dated 28 April 2021
6. Letter dated 24 May 2021
7. Letter dated 10 June 2021
8. Email dated 12 July 2021
9. Email dated 5 November 2021
10. Letter dated 19 August 2022
11. Email dated 6 September 2022
12. Email dated 21 September 2022
13. Email dated 9 November 2022
14. Email dated 14 February 2023

Mr David Evans ACA is therefore liable to disciplinary action under Disciplinary Bye-law 4.1c (effective between 14 October 2019 and 31 May 2023).

Allegation 6

6. Between 25 January 2022 and 21 July 2022, Mr David Evans ACA, on behalf of ‘Firm B’, failed to respond to the Practice Assurance Closing Record 
   following QAD’ s review on 26 April to 30 September 2021, within 15 business days, contrary to Practice Assurance Regulation 20 (effective 1 July 2019 to 31 May 2023).

Mr David Evans is therefore liable to disciplinary action under Disciplinary Bye-law 4.1c (effective between 14 October 2019 and 31 May 2023).

Allegation 7

7. Between 25 January 2022 and 21 July 2022, Mr David Evans ACA, on behalf of ‘The Firm’, failed to respond to the Practice Assurance Closing Record following QAD’s review on 26 April to 30 September 2021, within 15 business days, contrary to Practice Assurance Regulation 20 (effective 1 July 2019 to 31 May 2023).

Mr David Evans ACA is therefore liable to disciplinary action under Disciplinary Bye-law 4.1c (effective between 14 October 2019 and 31 May 2023).

Allegation 8

8. Between 1 July 2010 to 30 June 2021, Mr David Evans ACA, on behalf of ‘The Firm’, failed to notify ICAEW of a change to the composition of the firm, when a connected entity, ‘Firm C’, was appointed as a member, within 10 business days.

Mr David Evans ACA’s conduct was contrary to Practice Assurance Regulation 9.a (effective 1 January 2008 to 30 June 2019) and/or Practice Assurance Regulation 13.a (effective 1 July 2019 to 31 May 2023).

Mr David Evans is therefore liable to disciplinary action under Disciplinary Bye-law 4.1c (effective until 28 September 2011, from 29 September 2011 to 23 July 2013, 24 July 2013 to 31 December 2015, 1 January 2016 to 2 October 2016, 3 October 2016 to 10 October 2017, 11 October 2017 to 14 October 2018, 15 October 2018 to 13 October 2019 and 14 October 2019 to 31 May 2023). 

Allegation 9

9. Between 1 July 2010 to 30 June 2021, Mr David Evans ACA, as principal of ‘The Firm’, failed to comply with the Regulations governing the use of the description Chartered Accountants and general affiliates of ICAEW in that, between the following dates used the description Chartered Accountants when it was not entitled to do so:
1. 1 July 2010 and 18 June 2017 was in breach of Regulation 6 Governing the Use of Chartered Accountant and ICAEW Affiliates (effective from 1 March 2010 to 2 February 2016 and from 3 February 2016 to 18 June 2017); and/ or
2. 19 June 2017 and 9 July 2018 was in breach of Regulation 12 Governing the use of Chartered Accountant and ICAEW General Affiliates (effective from 19 June 2017 to 31 May 2023)

Mr David Evans is therefore liable to disciplinary action under Disciplinary Bye-law 4.1c (effective until 28 September 2011, from 29 September 2011 to 23 July 2013, 24 July 2013 to 31 December 2015, 1 January 2016 to 2 October 2016, 3 October 2016 to 10 October 2017, 11 October 2017 to 14 October 2018, 15 October 2018 to 13 October 2019 and 14 October 2019 to 31 May 2023).

Allegation 10

10. Between 1 July 2010 and 30 June 2021, Mr David Evans ACA, as principal of ‘The Firm’, failed to ensure that ‘The firm’ was supervised by an appropriate anti-money laundering supervisory authority contrary to:
1. Parts 1-6 of The Money Laundering Regulations 2007 (effective 15 December 2007 until 25 June 2017); and/ or
2. Regulation 8, and Parts 1-6 and 8-11 of The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (effective from 26 June 2017).

Mr David Evans ACA is therefore liable to disciplinary action under Disciplinary Bye-law 4.1a (effective between 14 October 2019 and 31 May 2023).

Mr David Lloyd Evans is therefore liable to disciplinary action under the Disciplinary Bye-laws.

Finding:

Allegations found proved on Me Evan’s own admission

Order:

Allegations 1b, 2, 3, 4, 5, 6 and 7 - ordered a severe reprimand with a fine of £30,000
Allegations 8, 9 and 10 - ordered a reprimand with a fine for Allegation 8 of £1,000
Pay costs of £25,525

This decision may be subject to appeal

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Disciplinary Committee – tribunal summary of decision

Mr Peter Ian Brealey of Hinckley, United Kingdom

A tribunal of the Tribunals Committee made the decision recorded below having heard the formal allegations on 15 and 16 October 2024 and 12 December 2024

Type of Member Member

Terms of Allegation

1. On or before 27 July 2018, Mr Peter Brealey FCA was responsible for the preparation of the following for ‘A’ Ltd for the year ended 31 October 2017 when he knew that they were incorrect as they were prepared using estimated figures:
   1. Accounts; and / or
   2. Corporation Tax Return.

In doing so Mr Peter Brealey FCA breached section 110.2 of the Code of Ethics (effective 1 January 2011 to 31 December 2019)

 Mr Peter Brealey FCA is therefore liable to disciplinary action under Disciplinary Byelaw 4.1a.

2. On or before 30 January 2019, Mr Peter Brealey FCA was responsible for the preparation of Mr ‘B’s tax return for the 2017/18 tax year which was incorrect in that:
   1.  Mr ‘B’s dividend from ‘A’ Ltd had been estimated and the
      tax return did not declare that it contained provisional or estimated figures;
      and / or
   2. Salary Mr ‘B’ had received was not included in the tax return.

   In doing so Mr Peter Brealey FCA breached section 130.1 and / or section 130.5 of the Code of Ethics (effective 1 January 2011 to 31 December 2019)

Mr Peter Brealey FCA is therefore liable to disciplinary action under Disciplinary Byelaw 4.1b.

3.  On or before 30 January 2019, Mr Peter Brealey FCA authorised the submission of Mr ‘B’s 2017/18 tax return to HMRC, without it being reviewed or approved by Mr ‘B’.

In doing so, Mr Peter Brealey FCA failed to adhere to paragraphs 3.26 to 3.28 of the Professional Conduct in Relation to Taxation (PCRT) (effective 1 March 2017) and therefore breached section 130.1 and / or section 130.3 of the Code of Ethics (effective 1 January 2011 to 31 December 2019).

Mr Peter Brealey FCA is therefore liable to disciplinary action under Disciplinary Byelaw 4.1b.

Finding:
Allegations 1, 2 and 3 found proved

Order:
Severe Reprimand
To pay a fine of £7,500 and costs of £30,000

This decision may be subject to appeal 

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Tribunals Committee – tribunal summary of decision

Miss Khushboo Shahani of Europort, Gibraltar

A tribunal of the Tribunals Committee made the decision recorded below having heard a formal complaint on 10 December 2024

Type of Member Provisional Member

Terms of Allegation

1a. Between 22 January 2022 and 22 March 2022 Ms Khushboo Shahani claimed expenses for ICAEW exam fees totalling £206, from her employer, ‘A’ Ltd.

This conduct was dishonest because Ms Khushboo Shahani submitted the expense claims when she was aware that she had not incurred these expenses;

Ms Khushboo Shahani is therefore liable to disciplinary action under Disciplinary Bye-law 4.1a effective between 14 October 2019 and 31 May 2023.

2a. On or around 8 February 2022 Ms Khushboo Shahani claimed expenses for BPP training and study materials totalling £1,497.14 from her employer, ‘A’ Ltd.

This conduct was dishonest because Ms Khushboo Shahani knew that she had not incurred these expenses;

Ms Khushboo Shahani is therefore liable to disciplinary action under Disciplinary Bye-law 4.1a effective between 14 October 2019 and 31 May 2023.

3a. Between 14 May 2022 and 24 June 2023 Ms Khushboo Shahani provided information to her employer ‘A’ Ltd about the ICAEW exams set out in Schedule A, stating that she had passed any or all of these exams when she had not done so.

This conduct was dishonest because Ms Khushboo Shahani knew at the time she provided the information that she had not passed any or all the exams listed in Schedule A;

Ms Khushboo Shahani is therefore liable to disciplinary action under Disciplinary Bye-law 4.1a effective between 14 October 2019 and 31 May 2023.

5a. On or around 23 June 2022 Ms Khushboo Shahani provided information to the Professional Conduct Department at ICAEW about the ICAEW exams set out in Schedule A, stating she had booked and / or paid for any or all these exams when she had not done so.

This conduct was dishonest because Ms Khushboo Shahani she knew that at the time she provided the information that she had not sat or paid for any or all the exams listed in Schedule A.

Ms Khushboo Shahani is therefore liable to disciplinary action under Disciplinary Bye-law 4.1a effective between 14 October 2019 and 31 May 2023.

Schedule A

Per Ms Shahani Spreadsheet:	Date Booked	Date of Exam	Date of Result	Result
KBF - Business Tech and Finance	02/08/2019	03/08/2019	04/08/2018	PASS
KAC -Accounting	07/08/2019	19/08/2019	20/08/2019	PASS
LAW - Law	25/11/2019	06/12/2019	07/12/2019	PASS
KMI - Management Information	06/09/2019	13/09/2019	14/09/2019	PASS
KTX - Principles of Taxation	02/10/2019	10/10/2019	11/10/2019	PASS

Schedule B

(as per Ms Shahani’s CV) ACA Professional level Tax Compliance December 2020 (70%) Audit and Assurance June 2020 (84%) Financial Reporting and Accounting December 2019 (76%) ACA Certificate level 2017 to 2018 Accounting (82%) Assurance (87%) Management Information (76%) Law (65%) Tax (72%) Business, Technology and Finance (92%)

Finding:
Allegations found proved

Order:
Status as a provisional member is withdrawn
Pay a financial penalty of £10,000
Pay costs of £15,545

This decision may be subject to appeal

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Tribunals Committee – tribunal summary of decision

Mr Paul Keith Matthews FCA of East Sussex, United Kingdom

A tribunal of the Tribunals Committee made the decision recorded below having heard formal allegations on the 06 December 2024.

Type of Member Member

Terms of allegations

4. Between 5 December 2012 and 26 February 2016, Mr Paul Keith Matthews FCA, on behalf of ‘Firm A’, signed unqualified audit opinions on the financial statements of ‘Firm B’. The audit reports stated that the audit was conducted in accordance with International Standards on Auditing (‘ISA’), when it was not, in that the audit did not comply with ISA 500 ‘Audit Evidence’ as the auditor failed to obtain sufficient appropriate evidence in relation to a loan payable amount for the following financial periods:
   1. year ended 31 May 2012, audit report dated 5 December 2012; and/or
   2. year ended 31 May 2013, audit report dated 28 February 2014 and/or
   3. year ended 31 May 2014, audit report dated 26 February 2015; and/or
   4. year ended 31 May 2015, audit report dated 26 February 2016.

In so doing, Mr Paul Keith Matthews FCA failed to comply with s.130.1 ICAEW’s Code of Ethics (effective 1 January 2011 to 31 December 2019).

Mr Paul Keith Matthews FCA is therefore liable to disciplinary action under DBL 4.1b (effective 29 September 2011, 24 July 2013 and 1 January 2016 to 2 October 2016).

5. Between 5 December 2012 and 5 May 2017, Mr Paul Keith Matthews FCA, on behalf of ‘Firm A’, signed unqualified audit opinions on the group financial statements of ‘Firm C’. The audit reports stated that the audit was conducted in accordance with International Standards on Auditing (‘ISA’), when it was not, in that the audit did not comply with ISA 500 ‘Audit Evidence’ as the auditor did not obtain sufficient appropriate evidence in relation to a loan payable amount for the following financial periods:
   1. year ended 31 May 2012, audit report dated 5 December 2012; and/or
   2. year ended 31 May 2013, audit report dated 3 December 2013 and/or
   3. year ended 31 May 2014, audit report dated 26 February 2015; and/or
   4. year ended 31 May 2015, audit report dated 26 February 2016; and/or
   5. year ended 31 May 2016, audit report dated 5 May 2017.

In so doing, Mr Paul Keith Matthews FCA failed to comply with s.130.1 ICAEW’s Code of Ethics (effective 1 January 2011 to 31 December 2019).

Mr Paul Keith Matthews FCA is therefore liable to disciplinary action under DBL 4.1b (effective 29 September 2011, 24 July 2013, 1 January 2016 and 3 October 2016 to 10 October 2017).

6. On 5 June 2018, Mr Paul Keith Matthews FCA, on behalf of ‘Firm A’, signed an unqualified audit opinion on the group financial statements of ‘Firm C’ for the year ended 31 May 2017. The audit report stated that the audit was conducted in accordance with International Standards on Auditing (‘ISA’), when it was not, in that, the audit did not comply with ISA 500 ‘Audit Evidence’ because the auditor did not obtain sufficient and appropriate evidence in relation to certain liabilities.

In so doing, Mr Paul Keith Matthews FCA failed to comply with s.130.1 ICAEW’s Code of Ethics (effective 1 January 2011 to 31 December 2019).

Mr Paul Keith Matthews FCA is therefore liable to disciplinary action under DBL 4.1b (effective 11 October 2017 to 14 October 2018).

7. On or around 17 July 2012, Mr Paul Keith Matthews FCA prepared and filed dormant accounts for ‘Firm D’ for the year ended 31 October 2011 when ‘Firm D’ was not a dormant company as defined in section 1169 of Companies Act 2006.

In so doing, Mr Paul Keith Matthews FCA failed to comply with s.130.1 ICAEW’s Code of Ethics (effective 1 January 2011 to 31 December 2019).

Mr Paul Keith Matthews FCA is therefore liable to disciplinary action under DBL 4.1b (effective 29 September 2011 to 23 July 2013).

Mr Paul Keith Matthews is therefore liable to disciplinary action under Disciplinary Bye-law 4.1b effective 29 September 2011 to 2 October 2016, 3 October 2016 – 10 October 2017 and 11 October 2017 – 14 October 20181.

Finding: Allegation found proved on Mr Matthew’s own admission

Order:
Severely Reprimanded
Fined £7,000
Pay costs of £7,500

This decision may be subject to appeal

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Tribunals Committee – tribunal summary of decision

Mr John Sudworth ACA of Kent, United Kingdom

A tribunal of the Tribunals Committee made the decision recorded below having heard a formal allegation on the 03 December 2024.

Type of Member Member

Terms of allegation

Between 10 May 2023 and 26 May 2023 Mr John Sudworth ACA failed to provide the information, explanations and documents requested by letter dated 10 May 2023, issued in accordance with Disciplinary Bye-law 13.1, contrary to Disciplinary Bye-law 13.2.

Mr John Sudworth ACA is therefore liable to disciplinary action under Disciplinary Bye-law 4.1c

Finding: Allegation found proved on Mr Sudworth’s own admission

Order:
Severely Reprimanded
Fined £8,500
Pay costs of £5,110
Provide all outstanding PII cover and annual returns to the ICAEW no later than 4pm on the 20^th December 2024

This decision may be subject to appeal

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Disciplinary Committee – tribunal summary of decision

Mr Gavin Roland Williams (FCA) of Bedfordshire, United Kingdom

A Tribunal of the Tribunal’s Committee made the decision recorded below having heard a formal allegation on 16 to 20 September 2024 and 7 November 2024

Type of Member Member

Terms of Allegations

1. Between 26 November 2019 and 14 December 2020 Mr Gavin Roland Williams, FCA, on behalf of ‘A’, failed to comply with Audit Regulation 3.09 in that he failed to allow access to any or all of the documents and information in Schedule A regarding ‘B’ for the year ended 31 August 2018, insofar that he did not provide them when requested by ‘C’:

Schedule A

No.	CMC Audit Information requested by ‘C’ in respect of audit report for year ended 31 August 2018	Dates information requested by ‘C’
1	Fixed asset register	26 November 2019 17 April 2020 18 May 2020
2	Breakdown of debtors/ other debtors	26 November 2019 17 April 2020 18 May 2020
3	Breakdown of prepayments	26 November 2019 17 April 2020 18 May 2020
4	Trade creditor report	26 November 2019 17 April 2020 18 May 2020
5	Breakdown of accruals and other creditors	26 November 2019 17 April 2020 18 May 2020
6	Other relevant schedules	26 November 2019
7	Details of the ‘D’	17 April 2020 18 May 2020
8	Details of the ‘E’	17 April 2020 18 May 2020
9	Audit approach plan	18 May 2020
10	Testing of designated fund and restricted fund	18 May 2020
11	Final Analytical Review	18 May 2020
12	Letter of representation	18 May 2020
13	Letter of comment/keys issues report to client	18 May 2020
14	Tests of donations received	18 May 2020
15	Tests of investments	18 May 2020
16	Large and unusual bank transactions test	18 May 2020
17	Review of key law or regulations for the client	18 May 2020
18	Test of accounting estimates	18 May 2020

Mr Williams is therefore liable to disciplinary action in accordance with Disciplinary Bye-law 4.1b effective from 14 October 2019 to 31 May 2023.

2. Between 15 May 2020 and 18 May 2020 Mr Gavin Roland Williams, FCA, failed to comply with paragraph R115.1 and/or paragraph R115.1A2 of the Code of Ethics (professional behaviour) effective from 01 January 2020, in that he made any or all of the comments set out in Schedule B to and/or about ‘F’ of ‘C’:

Schedule B

No.	Date and method of communication	Comment within the communication
1	Mr Williams emailed ‘F’ on 15 May 2020 at 15:36	“Any idiot could have done this by now…” “p.s. I will be telling your client, my friends, about all of this.”
2	Mr Williams emailed ‘F’ on 15 May 2020 at 17:05	“are you that incompetent?”.
3	On 16 May 2020, Mr Williams emails ‘C’ new client, ‘G’, copying in ‘F’, Ms ‘I’ and PCD and makes personal comments about ‘F’	“you have a meal om [sic] your plate with this auditor who even needs toilet roll bought for her…I’m a bit angry with her horse riding conduct (yes she rides horses)”.
4	Mr Williams sends a further email on 17 May 2020 to the client copying in ‘F’ and PCD	“I see no reason for your complaint, so get off your pony, get on a horse and then I will listen to you.”

Mr Gavin Roland Williams, FCA, is therefore liable to disciplinary action in accordance with Disciplinary Bye-law 4.1a effective from 14 October 2019 to 31 May 2023.

3. On 31 March 2019 Mr Gavin Roland Williams FCA, on behalf of ‘A’, signed an unqualified audit opinion on the financial statements of ‘B’ for the year ended 31 August 2018 which stated the audit had been conducted in accordance with ISAs (UK) and that the accounts had been properly prepared in accordance with United Kingdom Generally Accepted Accounting Practice when:
   1. the audit was not conducted in accordance with International Standard on Auditing 500 “Audit Evidence” because the auditor did not obtain sufficient appropriate audit evidence in relation to the following areas:
      1. Income; and/or
      2. Fixed Assets; and/or
      3. Creditors;

   And/or

   2. the audit was not conducted in accordance with International Standard on Auditing 230 “Audit Documentation” because the auditor did not prepare documentation that provided sufficient and appropriate record of the basis for the auditor’s report; and/or
   3. the audit was not conducted in accordance with International Standard on Auditing 300 “Planning” because the auditor did not sufficiently plan the audit to obtain sufficient and appropriate audit evidence for the basis for the auditor’s report; and/or
   4. the audit was not conducted in accordance with International Standard on Auditing 570 “Going Concern” because the auditor did not obtain sufficient appropriate audit evidence in relation to going concern; and/or
   5. The financial statements were not compliant with the Charities SORP 2015, FRS 102 in respect of the accounting treatment regarding the omitted statement of cash flows.

Mr Gavin Roland Williams, FCA, is therefore liable to disciplinary action in accordance with Disciplinary Bye-law 4.1b effective from 15 October 2018 to 13 October 2019.

4. On 23 October 2018 Mr Gavin Roland Williams FCA, on behalf of ‘A’, signed an unqualified audit opinion on the financial statements of ‘H’ for the year ended 31 March 2018 which stated the audit had been conducted in accordance with ISAs (UK) and that the accounts had been properly prepared in accordance with United Kingdom Generally Accepted Accounting Practice when:
   1. the audit was not conducted in accordance with International Standard on Auditing 500 “Audit Evidence” because the auditor did not obtain sufficient appropriate audit evidence in relation to the following areas:
      1. Creditors, and/or
      2. Income,

   And/or

   2. the audit was not conducted in accordance with International Standard on Auditing 230 “Audit Documentation” because the auditor did not prepare documentation that provided sufficient and appropriate record of the basis for the auditor’s report; and/or
   3. the audit was not conducted in accordance with International Standard on Auditing 300 “Planning” because the auditor did not sufficiently plan the audit to obtain sufficient and appropriate audit evidence for the basis for the auditor’s report; and/or
   4. the audit was not conducted in accordance with International Standard on Auditing 570 “Going Concern” because the auditor did not obtain sufficient appropriate audit evidence in relation to going concern; and/or
   5. The financial statements were not compliant with Charities SORP 2015 FRS102.

Mr Gavin Roland Williams, FCA, is therefore liable to disciplinary action in accordance with Disciplinary Bye-law 4.1b effective from 15 October 2018 to 13 October 2019.

5. On 27 September 2018 Mr Gavin Roland Williams FCA, on behalf of ‘A’, signed an unqualified audit opinion on the financial statements of ‘J’ for the year ended 31 March 2018 which stated the audit had been conducted in accordance with ISAs (UK) and that the accounts had been properly prepared in accordance with United Kingdom Generally Accepted Accounting Practice when:
   1. the audit was not conducted in accordance with International Standard on Auditing 500 “Audit Evidence” because the auditor did not obtain sufficient appropriate audit evidence in relation to the following areas:
      1. Income; and/or
      2. Trade debtors; and/or
      3. Accrued income

   And/or;

   2. the audit was not conducted in accordance with International Standard on Auditing 230 “Audit Documentation” because the auditor did not prepare documentation that provided sufficient and appropriate record of the basis for the auditor’s report; and/or
   3. the audit was not conducted in accordance with International Standard on Auditing 300 “Planning” because the auditor did not sufficiently plan the audit to obtain sufficient and appropriate audit evidence for the basis for the auditor’s report; and/or
   4. the audit was not conducted in accordance with International Standard on Auditing 570 “Going Concern” because the auditor did not obtain sufficient appropriate audit evidence in relation to going concern; and/or
   5. The financial statements were not compliant with the Charities SORP 2015, FRS 102 in respect of the accounting treatment regarding the omitted statement of cash flows.

Mr Gavin Roland Williams, FCA, is therefore liable to disciplinary action in accordance with Disciplinary Bye-law 4.1b effective from 11 October 2017 to 14 October 2018.

6. Between 18 December 2020 and 17 December 2021, Mr Gavin Roland Williams, FCA, provided PCD with some or all of the documents in Schedule C, belonging to the audit file of ‘B’ for the year ended 31 August 2018.

   The above is said to breach paragraph R111.1 and/or R111.A1 of the Code of Ethics in that the documents provided were presented to PCD on the basis that they had been used to support the audit opinion dated 31 March 2019 when this was not the case. Mr Williams conduct was therefore not straightforward and/or truthful.

Schedule C

No.	Date Document Provided	Document
1	8 February 2021	Planning and Completion Memo – not dated
2	18 December 2020	‘K’ Title deed dated 18 December 2020
3	18 December 2020	‘L’ Title deed dated 18 December 2020

Mr Gavin Roland Williams, FCA, is therefore liable to disciplinary action in accordance with Disciplinary Bye-law 4.1a effective from 14 October 2019 to 31 May 2023.

7. Between 12 February 2023 and 25 March 2023 Mr Gavin Roland Williams, FCA, failed to comply with Paragraph R115.1 and/or paragraph 115.1A2 of the Code of Ethics (professional behaviour) effective from 01 January 2020 in that he made any or all of the comments set out in Schedule D to ‘M’ about ‘N’ and/or ‘M’, both of ICAEW’s Professional Conduct Department.

Schedule D

No.	Date and method of communication	Comment within the communication
1	Mr Williams emailed ‘M’ on 12 February 2023	“I am sure you can see how stupid ‘N’ is making all of us look”
2	Mr Williams sends an e-mail to ‘M’ dated 24 February 2023	“M’, I told you that ‘N’ is corrupt.”
3	Mr Williams provides an e-mail on 17 March 2023 to ‘M’ responding to a further query.	“If it may help, I've attached a recent land registry search which confirms that your primary question was a load of bollox.” “Please include this comment in your "draft" report, once you are able to do your job.”
4	Mr Williams provides an e-mail to ‘M’ on 24 March 2023	“This is to ensure that you can't make up anything further (such as the land registry search)…”

Mr Gavin Roland Williams, FCA, is therefore liable to disciplinary action in accordance with Disciplinary Bye-law 4.1a effective from 14 October 2019 to 31 May 2023.

Finding: Allegations Proved

Order:
Exclusion from membership of ICAEW (allegation 6)
Severely reprimanded (allegations 1,2,3,4,5 and 7)
A fine of £29,500 and costs of £43,015 reduced on the grounds of limited means to an order to pay £20,000 as a contribution towards the fine and costs.

This decision may be subject to appeal 

---

Tribunals Committee – tribunal summary of decision

Botros & Co of Leeds, United Kingdom

A tribunal of the Tribunals Committee made the decision recorded below having heard a formal allegation on 21 October 2024

Type of Member Member Firm

Terms of Allegation

Between 6 June 2017 and 31 August 2022, Botros & Co failed to disclose to ICAEW that the firm had audit clients and received income from providing audit services on its annual returns for the following years:

a. 2017 and / or
b. 2018 and / or
c. 2019 and / or
d. 2020 and / or
e. 2021 and / or
f. 2022

This was in breach of Audit Regulation 2.10A and/or Audit Regulation 6.06.

Botros & Co is therefore liable to disciplinary action under Disciplinary Bye-law 6.2a.

Finding: Allegation found proved

Order:

Reprimanded
Pay a Financial Penalty of £3,500
Pay costs of £11,250

This decision may be subject to appeal

---

Tribunals Committee - tribunal summary of decision

Mrs Shelagh Brownlow-Cloete [FCA] of Darwen, United Kingdom

A tribunal of the Tribunals Committee made the decision recorded below having heard formal allegations on 14 August 2024.

Type of Member Member

Terms of Allegations

1. Between 30 November 2020 and 18 January 2021 Mrs Shelagh Brownlow-Cloete FCA, failed to act diligently in that she:
   1. Did not provide members of ‘A’ LLP with their profit share information by the agreed deadline of 30 November 2020; and / or
   2. Did not file ‘A’ LLP’s 31 August 2019 financial statements at Companies House by 31 August 2020.

   Her actions are contrary to R113.1 (b) of ICAEW’s Code of Ethics (effective from 1 January 2020).

   Mrs Shelagh Brownlow-Cloete is therefore liable to disciplinary action pursuant to DBL 4.1.b (effective from 14 October 2019 – 31 May 2023).

2. On or before 28 February 2021, Mrs Shelagh Brownlow-Cloete FCA authorised the submission of Ms ‘B’s 2019/2020 tax return to HMRC, without it being reviewed or approved by Ms ‘B’.

   In doing so, Mrs Shelagh Brownlow-Cloete FCA failed to adhere to paragraphs 3.26 to 3.28 of the Professional Conduct in Relation to Taxation (PCRT) (effective 1 March 2017) and therefore breached subsection R113 of the Code of Ethics (effective 1 January 2020).

   Mrs Shelagh Brownlow-Cloete FCA is therefore liable to disciplinary action under Disciplinary Bye-law 4.1.a (effective from 14 October 2019 – 31 May 2023).

3. Between 30 August 2020 and 31 May 2021, Mrs Shelagh Brownlow-Cloete FCA submitted either or both of the forms set out below at Companies House on behalf of ‘A’ LLP which shortened the year end by 1 day without authorisation:

   Form	Date submitted
   a) LLAA01 Change of accounting reference date	31 August 2020
   b) LLAA01 Change of accounting reference date	30 May 2021

   
   

   Mrs Shelagh Brownlow-Cloete action’s lacked integrity in that she knew that she did not have the authorisation to change the year end date.

   Mrs Shelagh Brownlow-Cloete’s conduct was contrary to the Fundamental Principle of Integrity R111 of ICAEW’s Code of Ethics (Effective 1 January 2020).

   Mrs Shelagh Brownlow-Cloete is therefore liable to disciplinary action pursuant to DBL 4.1.a (effective from 14 October 2019 – 31 May 2023).

4. Between 17 December 2020 and 8 March 2021 Mrs Shelagh Brownlow-Cloete FCA failed to act diligently in that she did not reply to any or all of the correspondence from Ms ‘B’ in schedule A:

   Schedule A

   Date	Method of correspondence
   a) 17 December 2020	Email
   b) 7 January 2021	Email
   c) 12 January 2021	Email
   d) 8 February 2021	Email
   e) 15 February 2021	Email
   f) 23 February 2021	Email
   g) 1 March 2021	Email
   h) 4 March 2021	Email

   
   

   Mrs Shelagh Brownlow-Cloete’s conduct was contrary to R113 of ICAEW’s Code of Ethics (effective from 1 January 2020).

   Mrs Shelagh Brownlow-Cloete is therefore liable to disciplinary action pursuant to DBL 4.1.b (effective from 14 October 2019 – 31 May 2023).

5. Between 1 April 2020 and 30 September 2021 Mrs Shelagh Brownlow-Cloete FCA did not act with diligence as she failed to:

   1. file the statutory accounts of ‘C’ Limited for the year ended 31 March 2020 at Companies House by the required filing deadline of 31 March 2021: and/or
   2. file the corporation tax return and CT600 of ‘C’ Limited for the year ended 31 March 2020 with HMRC by the required filing deadline of 31 March 2021; and/or
   3. file the personal tax return of Mr ‘D’ for the tax year 2019/2020 with HMRC by the required filing deadline of 31 January 2021.
   
   

   Mrs Shelagh Brownlow-Cloete’s actions were contrary to R113 of ICAEW’s Code of Ethics (effective 1 January 2020).

   Mrs Shelagh Brownlow-Cloete is therefore liable to disciplinary action pursuant to DBL 4.1.b (effective from 14 October 2019 – 31 May 2023).

6. On 31 March 2021 Mrs Shelagh Brownlow-Cloete FCA submitted a document to Companies House shortening the year end of ‘C’ Limited by 1 day from 31 March 2020 to 30 March 2020 at Companies House which contained a materially false/misleading statement. Her actions were contrary to R111 (integrity) of ICAEW’s Code of Ethics (Effective 1 January 2020).

   Mrs Shelagh Brownlow-Cloete’s conduct lacked integrity because she knew that she did not have the approval and / or authorisation of the members of ‘C’ Limited to change the date.

   Mrs Shelagh Brownlow-Cloete is therefore liable to disciplinary action pursuant to DBL 4.1.a (effective from 14 October 2019 – 31 May 2023).

7. Between 20 July 2021 and 29 September 2021, Mrs Shelagh Brownlow-Cloete FCA failed to provide handover information in relation to ‘C’ Limited as requested by Mr ‘E’ FCA of ‘F’ Ltd on 20 July 2021, contrary to R320.7 of ICAEW’s Code of Ethics (effective from 1 January 2020).

   Mrs Shelagh Brownlow-Cloete is therefore liable to disciplinary action pursuant to DBL 4.1.a (effective 14 October 2019 – 31 May 2023

8. Between 30 January 2019 and 20 April 2020 Mrs Shelagh Brownlow-Cloete FCA, failed to act diligently in that she:
   1. Did not file Mr ‘G’s correct 2017/2018 Self-Assessment Tax return by the required filing deadline of 31 January 2019; and / or
   2. Did not file Mr ‘G’s amended 2017/2018 Self-Assessment Tax return within two weeks of submitting the estimated return on 31 January 2019 as originally stated; and /or
   3. Did not file Mr ‘G’s 2018/2019 Self-Assessment Tax return by the required filing deadline of 31 January 2020
   
   

   Her actions are contrary to 130.1 (b) of ICAEW’s Code of Ethics (effective 1 January 2011) and / or R113.1 (b) of ICAEW’s Code of Ethics (effective from 1 January 2020).

   Mrs Brownlow-Cloete is therefore liable to disciplinary action pursuant to DBL 4.1.b (effective from 15 October 2018 to 13 October 2019 and 14 October 2019 to 31 May 2023).

9. Between 30 January 2019 and 20 April 2020 Mrs Shelagh Brownlow-Cloete FCA authorised the submission of Mr ‘G’s tax returns to HMRC, for the years listed below without them being reviewed and/or approved by Mr ‘G’;

   1. 2017/18 tax return; and / or
   2. 2017/18 amended tax return; and / or
   3. 2018/19 tax return.
   
   

   In doing so, Mrs Shelagh Brownlow-Cloete FCA failed to adhere to paragraphs 3.26 to 3.28 of the Professional Conduct in Relation to Taxation (PCRT) (effective 1 March 2017) and therefore breached subsection R113 of the Code of Ethics (effective 1 January 2020).

   Mrs Shelagh Brownlow-Cloete FCA is therefore liable to disciplinary action under Disciplinary Bye-law 4.1.a (effective from 15 October 2018 to 13 October 2019 and 14 October 2019 to 31 May 2023).

10. Between 2 May 2021 and 27 October 2021 Mrs Shelagh Brownlow-Cloete FCA failed to act diligently in that she did not reply to any or all of the correspondence from Mrs ‘H’ in schedule B:

    Schedule B

    Date	Method of correspondence
    a. 3 May 2021	Email
    b. 18 May 2021	Email
    c. 18 June 2021	Email
    d. 13 July 2021	Email
    e. 26 October 2021	Email

    
    

    Mrs Shelagh Brownlow-Cloete’s conduct was contrary to 130 of ICAEW’s Code of Ethics (effective from 1 January 2011) and R113 of ICAEW’s Code of Ethics (effective from 1 January 2020).

    Mrs Brownlow-Cloete is therefore liable to disciplinary action pursuant to DBL 4.1.b (effective from 15 October 2018 to 13 October 2019 and 14 October 2019 – 31 May 2023).

11. Between 16 November 2021 and 17 February 2022, Mrs Shelagh Brownlow-Cloete FCA failed to provide handover information in relation to Mr ‘G’ as requested by Mr ‘I’ of ‘J’ on 16 November 2021, contrary to R320.7 of ICAEW’s Code of Ethics (effective from 1 January 2020).

    Mrs Shelagh Brownlow-Cloete is therefore liable to disciplinary action pursuant to DBL 4.1.b (effective from 14 October 2019 – 31 May 2023).

Finding: All allegations proved on Mrs Brownlow-Cloete’s own admission

Order:
Excluded from membership of ICAEW
Pay costs of £23,280

This decision may be subject to appeal.

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