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ACCA Strategic Professional · Advanced Audit and Assurance (International) · Money laundering

Zeta Co, an audit client, sells goods to a customer who pays through a third party in an unrelated country, then requests a refund of part of the payment to a different bank account. The auditor suspects the transaction is intended to convert criminal funds into a clean refund. A junior argues that no offence by the auditor can arise unless the auditor personally handled the funds. Which response is most accurate?

The junior is wrong. Auditors can commit offences by failing to report knowledge or suspicion of money laundering gained during their work, even if they never handled the funds. No conviction of the client is required, and professional confidentiality does not override statutory reporting duties.

  1. AIncorrect; an auditor can commit an offence by failing to report knowledge or suspicion gained in the course of work, even without handling fundsCorrect
  2. BCorrect; offences arise only for persons who physically hold the criminal property
  3. CIncorrect; the auditor is only liable if the client is convicted of the predicate offence
  4. DCorrect; auditors are exempt from money laundering offences because of confidentiality

Explanation

Money laundering legislation typically criminalises failure to report knowledge or suspicion acquired in the regulated sector, regardless of handling funds. Conviction of the client is not required, and confidentiality does not override the reporting duty, which is typically protected by statute.

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