ACCA Applied Knowledge · Business and Technology · Regulation and financial crime
An accountant has submitted a suspicious activity report about a client's transactions and is asked by the client why a routine payment has been delayed. Which response is most appropriate under typical anti-money laundering rules?
The accountant should not disclose the report or anything that could prejudice an investigation, and should take guidance from the MLRO and the authority. Telling the client or third parties would risk the offence of tipping off, even if the intention is to be helpful.
- AExplain that a report has been made so the client can provide further documents
- BSay nothing about the report and avoid any statement that could prejudice an investigation, taking guidance from the MLRO and the authorityCorrect
- CRefuse to speak to the client again and publicly end the relationship
- DTell the client's bankers about the report so they can monitor the account
Explanation
Disclosing that a report has been made, or that an investigation is under way, in a way likely to prejudice it is tipping off, which is an offence. The accountant should not reveal the report and should take guidance from the MLRO. Telling the bankers is also an unauthorised disclosure.
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