Disciplinary
Disciplinary
Publicity notices
Charge
In terms of ICAS Rule 13.21, notice is hereby given that the ICAS Investigation Committee has found an ICAS student member liable to disciplinary action on the following grounds:
“The student improperly completed an assessment, by using Artificial Intelligence (AI) – in the form of Microsoft Copilot – when they were not permitted to do so, in breach of the fundamental principle of integrity contained in the ICAS Code of Ethics.”
Sanction
Under operation of Investigation Regulation 2.16, the student has accepted an order of reprimand.
Commentary
- The Committee has reprimanded an ICAS student member after finding that in January 2025 they used AI assistance during their employing firm’s internal audit training assessment when the use of AI had been expressly prohibited.
- The student admitted using AI during the assessment to answer 27 questions. While the Committee accepted that there was no intention to deliberately deceive the firm and that the conduct occurred during a period of significant personal pressure, it concluded that the student’s use of AI in the assessment amounted to cheating.
- The Committee considered that the student’s conduct breached the fundamental principle of integrity contained in Section 111 of the ICAS Code of Ethics, which requires members and students to be straightforward and honest in all professional and business relationships. The Committee noted that section 111.1 A1 of the Code explains that “integrity involves fair dealing, truthfulness and having the strength of character to act appropriately, even when facing pressure to do otherwise or when doing so might create potential adverse personal or organisational consequences”. The Committee concluded that the conduct amounted to professional misconduct.
- In determining the sanction, the Committee had regard to ICAS’ Sanctions Guidance. It noted that the misconduct related to a single assessment, that the student demonstrated insight into their actions, admitted the matter at an early stage, and had no previous disciplinary history.
- The Committee also recognised the need to maintain confidence in the profession and to deter similar conduct by other students and members.
- Taking all factors into account, the Committee concluded that the matter could appropriately be disposed of by way of a consent order for reprimand.
- In light of the student’s personal mitigating circumstances, the Committee decided not to impose a financial penalty and made no award of investigation costs.
- On this occasion the Committee agreed not to identify the student member.
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 six firms for failing to comply with their statutory obligations under AML legislation as required in terms of Regulation 4.16 of the AML Regulations. The penalties ranged from £200 to £900.
The areas of non-compliance included:
- Failures in connection with the Supervised Firm’s AML policy.
- Failures in connection with the Supervised Firm’s whole firm compliance review.
- Failures in connection with the Supervised Firm’s Client Due Diligence requirements.
- Failure to provide training for the Supervised Firm’s Money Laundering Reporting Officer.
- Failures in connection with the Supervised Firm’s process for considering and making Suspicious Activity Reports.
In determining the amount of the penalties, the Committee had regard to 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.
