ACCA AAA UK Syllabus A. Regulatory Environment - Reporting Duties - Notes 9 / 11
Professional accountants must report money laundering to the appropriate authority (e.g. MLRO, Police).
Some Points about Reporting
It is a criminal offence not to report
Regardless of the amount or seriousness
There is no obligation to quantify the certainty of suspicion
There is no automatic need to cease working for a particular client where a report has been filed
Doing so may even be tipping off!
An external report should be made to the authorities
It should include the following
Name of the reporting business
Identification information of each person (DOB, address etc)
Role of each person (eg Suspect)
Any references seen (eg Bank account)
Details of suspicious transaction
Location of any laundered property
Resignation
You should consider resigning where..
It is in your commercial interests to do so
It is professionally and ethically responsible to do so
Just be careful to avoid tipping off. Again, legal advice should be sought if in doubt
What are suspicious transactions?
Large cash deposits
Unexplained foreign transactions
Transactions with no business explanation