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ACCA Applied Knowledge · Business and Technology · Regulation and financial crime

A firm's MLRO files a suspicious activity report about a client. Later the audit partner, wanting to be open, mentions to the client's finance director that a report has been made. Which offence has most likely been committed?

The partner has most likely committed tipping off. This offence arises when someone reveals that a suspicious activity report has been made or that an investigation is under way, in a way that could prejudice it. It differs from failing to report, which is a separate offence.

  1. ATipping offCorrect
  2. BFailure to disclose
  3. CInsider dealing
  4. DStructuring

Explanation

Tipping off is disclosing that a report has been made, or that an investigation is under way, in a way likely to prejudice that investigation. Failure to disclose concerns not reporting a suspicion. Structuring means breaking up transactions to avoid thresholds and insider dealing relates to price-sensitive information.

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