ACCA AAA ^INT Syllabus A. Regulatory Environment - Scope of Money Laundering - Notes ^{4 / 11}

These are the common ones under UK legislation but generally apply worldwide and hence in the exam..

1. Not appointing a Money Laundering Reporting Officer (MLRO)

2. Not having risk management procedures and internal controls complying with anti-ML legislation

3. Not verifying identity of all new clients

4. No ongoing client due diligence

5. Failure to report a suspicion of ML

6. Tipping off

7. Tax evasion

Tipping-off 
This is when an individual who is suspicious, discloses that suspicion to the suspect

In fact even non-disclosure/action may 
be considered tipping off (e.g. not carrying out a client's instructions that is effectively a money laundering operation).

If the client asks the accountant to commit a suspected ML offence, this must be reported to the appropriate authority 
Also not being suspicious is not a defence if it is clear that a reasonable person should have been suspicious

The fear of tipping off should not prevent the professional accountant from discussing money laundering matters with clients on a non-specific basis. Not doing so, when requested, may amount to tipping off.