Ethical and other professional issues

Generally ½ mark each issue identified + 1 mark each comment/action

Ideas
 (i) Tax investigation
 • new client (relatively) – CDD
 • ‘professional etiquette’ – change in professional appointment
 • quality control eg second review
 • criminal property includes proceeds of tax evasion
 • money laundering offence?
 • suspicion of fraud (intent) vs error in incorrect tax returns
 • disclosure by Dedza vs voluntary (confidentiality)
 • need for STR

(ii) Advice on payments
 • not a tax issue
 • corruption and bribery/extortion – designated categories of offence
 • clear intent
 • seriousness in context of domestic laws
 • need to report to FIU?

(iii) Financial advisor
 • designated non-financial profession
 • customer due diligence/record keeping
 • politically exposed person (PEP)
 • reputational risk
 • additional measures
 • refusal to act

(a) max 7
 (b) max 4
 (c) max 4