Confidentiality

Question 1

What are the safeguards to confidentiality?

Answer 1

Not discussing client matters in public, or with 3rd parties
Not leaving files unattended or in unsecured places
Not removing papers from office
Not working on systems that don’t have good protection

Question 2

When is disclosure allowed?

Answer 2

Consent has been obtained
Public duty - seek legal advice
Legal duty
Uncovered employee fraud
Terrorist activities
Regulatory breaches
Suspected money laundering

Question 3

What are examples of money laundering?

Answer 3

Keeping customer overpayments
Criminal offenses under Companies Act
Offenses involving a saved cost

Question 4

What are some suspicions of money laundering?

Answer 4

Credits on receivables
Unusual related parties transactions
Lack of expected costs
High number of cash transactions
Complicated group structure

Question 5

What does the Money Laundering Nominated Officer do?

Answer 5

Receive reports on suspected ML
Report to NCA

Question 6

What does the Money Laundering Compliance Principal Officer do?

Answer 6

Ensure the firm complies with regulations by training, documenting retention, client due diligence

Question 7

What are the safeguards in place for conflict of interest?

Answer 7

Disclose to each client
Informed consent of each client
Confidentiality agreements
Information barriers
Regular reviews by a senior not involved

Question 8

What are some information barriers?

Answer 8

No overlap in teams
Physical separation of teams
Careful procedures when info has to go past the barrier

Question 9

If the conflict cannot be managed, what do we do?

Answer 9

Not act - turn down the audit