Disciplinary
Disciplinary
Publicity notices
Colin Alexander Dempster CA
In terms of ICAS Rule 13.21, notice is hereby given that the ICAS Investigation Committee has found ICAS member Colin Alexander Dempster CA, of the firm Colin A Dempster based in Strathaven, guilty of professional misconduct in respect of the following charge:
On 7 and 29 July 2025, Mr Dempster submitted a “Firm Wide Money Laundering Risk Assessment Template” and an “AML Compliance Program” respectively to the ICAS Monitoring Team in which he made comments that were offensive and unprofessional in breach of the fundamental principle of Professional Behaviour contained in Section 115 of the Code of Ethics.
Sanction
Under operation of Investigation Regulation 2.15.3, 2.15.4 and 2.15.5, Mr Dempster has accepted an order of a severe reprimand, a financial penalty of £5,000 and a requirement to pay £1,670 towards the costs of the investigation.
Commentary
• In July 2025, the Investigation Committee received a referral from the ICAS Monitoring Team, relating to a number of comments that Mr Dempster made.
• The comments were made in two documents known as a “Firm-Wide Money Laundering Risk Assessment Template” and an “AML Compliance Program” which were submitted to ICAS as part of an Anti-Money Laundering (AML) monitoring visit that was scheduled to take place. The comments were considered to be offensive and unprofessional.
• The Investigation Committee was asked to consider a total of nine comments, which included comments relating to a number of protected characteristics.
• Mr Dempster did not dispute that he made the comments, nor that he submitted the relevant documents to the ICAS Monitoring Team.
• The Committee concluded that by making such offensive comments in documents which he submitted to ICAS as his professional regulatory body, Mr Dempster has breached the fundamental principle of professional behaviour and is guilty of professional misconduct.
• R115.1A of the ICAS Code of Ethics relates to professional behaviour and requires members to avoid any conduct that the accountant knows or should know might discredit the profession, which includes conduct that a reasonable and informed third party would be likely to conclude adversely affects the good reputation of the profession.
• In reaching its decision on sanction, the Committee had regard to the ICAS Sanctions Guidance, Part 4: “Ethical breaches”. While the Committee observed that the comments were not made in a public forum beyond ICAS, it was noted that they were made in a professional capacity. Taking account of the nature and number of the comments, the Committee considered that the breach was “serious”.
• Taking account of all relevant factors, the Committee concluded that the matter could be appropriately dealt with by way of a consent order for severe reprimand, together with a financial penalty and the reasonable costs of the investigation.
Xin Guo
Xin Guo, a student member, has been excluded from membership of ICAS and has been found liable for the costs totalling £6,035 following a Discipline Tribunal held in March 2026.
The Discipline Tribunal found Ms Guo guilty as follows:
During a Strategic Finance and Modelling assessment on 14 December 2022 and a Business Taxation assessment on 16 December 2022, she communicated with another student in order to obtain and/or provide assistance in the answering of the assessment questions and to gain and/or provide an unfair advantage, contrary to the ICAS Academic Integrity Policy and Exam Terms & Conditions. Her actions were dishonest, and she is thereby guilty of professional misconduct in terms of Rules 13.1, 13.5.1 and 13.5.2 of the ICAS Rules.
The full written decision of the Tribunal is available on the ICAS website.
Xiaoyu Zhang
Xiaoyu Zhang, a student member, has been excluded from membership of ICAS and has been found liable for the costs totalling £6,035 following a Discipline Tribunal held in March 2026.
The Discipline Tribunal found Ms Zhang guilty as follows:
During a Strategic Finance and Modelling assessment on 14 December 2022 and a Business Taxation assessment on 16 December 2022, she communicated with another student in order to obtain and/or provide assistance in the answering of the assessment questions and to gain and/or provide an unfair advantage, contrary to the ICAS Academic Integrity Policy and Exam Terms & Conditions. Her actions were dishonest and she is thereby guilty of professional misconduct in terms of Rules 13.1, 13.5.1 and 13.5.2 of the ICAS Rules.
The full written decision of the Tribunal is available on the ICAS website.
Regulatory
Gordon McIntyre
In terms of Regulation 5.33 of the ICAS Insolvency Regulations, notice is hereby given that the ICAS Authorisation Committee has applied a regulatory penalty of £2,500 to the Insolvency Practitioner (IP), Gordon McIntyre, in respect that, in three insolvency appointments, Mr McIntyre made a payment after the commencement of a winding-up without seeking valid approval in accordance with Rule 4.7(5) of the Insolvency (Scotland) (Receivership and Winding up) Rules 2018.
The Committee was satisfied that a regulatory penalty was appropriate in the circumstances. In reaching its decision on the amount of the penalty, the Committee had regard to the Common Sanctions Guidance for Insolvency Complaints (“the Guidance”), noting the indicative sanctions in Part 2 of the Guidance. The Committee assessed the level of seriousness of the conduct to be “serious”, on the basis that (i) in each case, the IP intended to draw the fee before his appointment and had obtained approval from the directors pre-appointment but the invoice was raised and drawn post-appointment, (ii) changes in the firm’s internal processes may have contributed to the error, but (iii) the issue had arisen on three of the IP’s cases. The indicative sanction in the Guidance for drawing unauthorised remuneration where the conduct is categorised as “serious” is £5,000. As a mitigating factor, the Committee noted that in each of the three cases the IP had repaid the fee and sought approval from creditors once the issue had been highlighted to him. The Committee therefore concluded that a penalty of £2,500 was appropriate in the circumstances.
Gibson McKerrell Burrows Limited
In terms of Regulation 7.14(b) of the Audit Regulations, notice is given that the ICAS Authorisation Committee has applied a regulatory penalty of £5,000 to the audit-registered firm of Gibson McKerrell Burrows Limited (firm number 4646). The firm has acknowledged that it failed to cooperate with ICAS, its monitoring unit and its monitoring arrangements, in breach of Regulations 2.08 and 2.09 of the Audit Regulations.
Regulatory Penalties for AML breaches
In terms of Regulation 5.25 of the ICAS Anti-Money Laundering Regulations (the AML Regulations), notice is given that the Authorisation Committee (the Committee) has applied regulatory penalties to two firms for failing to comply with their statutory obligations under Anti-Money Laundering Legislation as required in terms of Regulation 4.16 of the AML Regulations. The penalties were for £200 and £600.
The areas of non-compliance included:
- Failures in connection with the Supervised Firm’s customer due diligence (CDD) requirements.
- Failure to properly communicate / cooperate with ICAS in respect of AML matters.
In determining the amount of the penalties, the Committee had regard to the ICAS AML Regulatory Actions Guidance, which was revised in April 2025. As a temporary measure, during the transition to the revised Guidance, the Committee has decided that the firms should not be named when the penalties are publicised.
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