ACCA Applied Knowledge · Business and Technology · Ethical conflicts and dilemmas
Tomas, an accountant, suspects that his employer is laundering money through its accounts. He reports the suspicion to the firm's nominated money laundering reporting officer (MLRO), who decides there is no case. Tomas remains convinced. Which statement is most accurate regarding Tomas's position?
Tomas should take legal advice on his own obligations and consider whether external reporting is legally required, while avoiding tipping off those involved. Reporting internally does not necessarily end his duties, and telling the customer or going public would be inappropriate and possibly unlawful.
- AHaving reported internally, Tomas has no further obligations and may tell the customer concerned about the report
- BTomas should seek legal advice on his own position and consider whether external reporting is required by law, taking care not to tip off those involvedCorrect
- CTomas must resign immediately and publish his concerns to protect the public
Explanation
Where suspicion persists, the individual should take legal advice on their legal obligations and whether external reporting is required, while avoiding tipping off, which is itself an offence in many jurisdictions. Telling the customer would be tipping off. Publishing concerns publicly is disproportionate and may breach confidentiality.
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