Can you confirm if there are general offences (ie tipping off, tax evasion,failure to report and possession dealing with or concealing criminal property) under this act and also principle offences which are specific to the accountant/member (ie failure to apoint MLRO, failure to maintain records, failure to undertake verification of identity of all new clients before commencing a business relaionship etc).
wow Candice! the steps involved in laundering are placement, layering and integration.
The offences are laundering, tipping-off and failure to report
Does that help?
That part is cleared, thanks. I was just a bit confused based on some notes in my possession. I realised that there were some requirements of the company/mgmt under this act, like appointment of an MLRO, failure to maintain records, failure to undertake verification of identity of all new clients before commencing a business relaionship etc).
What is the sanction if any, should the company fails to ensure the implementation of these requirements.
I suppose, if things go wrong, the company could be held to be complicit in helping to launder. A former senior of FTCKaplan ( in a former name ) has just finished 6 years in prison for laundering!
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