Required Disclosure Flashcards
What are the 2 circumstances where a required disclosure or a SAR must be made?
When the accountant provides services to a client relating to property which may relate to money laundering or terrorist financing.
When the accountant knows or suspects another person is engaged in money laundering or terrorist financing.
As a minimum what should a SAR contain?
The identity of the suspected person
The information on which the suspicion of money laundering is based
The whereabouts of the laundered property if known
Details of the person making the report - MLRO or sole practitioner.
What is one example where an accountant should report to the firm’s MLRO, or the NCA, for sole practitioners?
Where, despite advice from their accountant, the client has not disclosed an omission on their tax affairs.
