Mr Iseolorunpo J Adegboye AFA MIPA
London, UK 

Complaint 

The IFA complaint was that Mr Adegboye as sole director of Addison James & Co Limited failed to: 

• adhere to the fundamental principle of professional behaviour in the Code of Ethics requirement R115.1 which imposes an obligation on all professional accountants ‘to comply with relevant laws and regulations and avoid any conduct that the accountant knows or should know might discredit the profession’; 
• provide requested information or documents in accordance with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), Regulation 66; 
• carry out a review of anti-money laundering policies, procedures and controls in accordance with MLR 2017 Regulation 19;  
• as a relevant person, has failed to carry out complete customer due diligence (CDD) on all clients and therefore breaching MLR 2017 Regulation 27 (a) and Regulation 28 in particular (1,2, 3, 4, 12, 13, 16, 18 and 19). For the purposes of IFA anti-money laundering (AML) supervision, the ‘relevant person’ is Addison James & Co Limited;  
• provide such information as is deemed necessary by the Institute for compliance and monitoring purposes breaching IFA Bye-law 12.2.  

Finding 

The Regulatory Committee found that there was a prima facie case to answer that rendered Mr Adegboye liable to disciplinary action under Bye-law 11 for breaches of Bye-law 12.2 and the Code of Ethics R115.1and breaches of Money Laundering Regulations 2017  66, 19, 27(a) and 28 (1, 2, 3, 4, 12, 13, 16, 18 and 19). 

Consent Order

Reprimand, fine £2,750 and costs of £515.