Chapter 16: Confidentiality

Question 1

What are the 4 conditions where there is a duty to disclose personal information?

Answer 1

1) If ordered by court
2) If required by a regulator
3) Suspicion on money laundering report to National Crime Agency
4) Suspicion of terrorist activities

Question 2

What are the 2 people each firm MUST have regarding money laundering?

Answer 2

1) Money laundering nominated officer
2) Money laundering compliance principle
(Could be the same person)

Question 3

What are examples of money laundering?

Answer 3

1) Keeping customer overpayments
2) Non-compliance with regulations to save costs
3) Criminal offences under companies act

Question 4

What happens when there is a conflict of interest between clients?

Answer 4

Notify the relevant clients and seek their consent to work for both.

Question 5

What safeguards can be put in place when working for 2 clients with conflicting interests?

Answer 5

• Seperate teams
• Information barriers
• Confidentiality agreements
• Reviews of the application of safeguards.