Q43 Thomasson

(a)

(i)

Anti-Money Laundering programme:

 Appointed a money laundering reporting officer (MLRO) with an appropriate level of experience
and seniority
 Established internal reporting lines which should be followed to report any suspicions –
standard form to report suspicions of money laundering to MLRO
 Content of typical form : name of suspect, amounts potentially involved, reasons for the
suspicions + supporting evidence
 Any suspicions of ML activities is then required to disclose these suspicions to the MLRO –
failure to report will be an offence of ML
 After receive internal report, MLRO consider all the information reported, document them and
decide whether to report the suspicions to the app external authorities – legal duty to report
even though this may conflict with auditor’s duty of confidentiality

(ii)

Possible indicators of ML activities:

Cash-intensive business

 Clean co – high level of cash-based +high volume of individual sales – nature of business creates
risk/opportunities to perform ML activites – do not clear business purpose
 Example : Mr Blackers sale to business associate for $33k may seems to be normal as part of
their way of selling products, but might be a way of placing illegal funds in order to legitimize
them as genuine sales as the amount involved is large

International property transactions

 Performance of Mr Balckers personal tax computation – significant number of transactions

involving purchase and sale of properties in international locations
 May be examples of real estate laundering
 Example : he may purchase these properties with illegal funds (placement) and then selling
them in order to make funds appear legitimate (integration)
 High volume of transactions and off-shore bank accounts under Mr Blackers name may indicate
the activity of layering to attempt to conceal the original sources of the proceeds