ICAEW BL · Chapter 13 · Question 4 of 10
Ruth, a trainee at a firm of accountants, learns that her firm's MLRO has submitted a suspicious activity report to the National Crime Agency about a client. Which of the following disclosures by Ruth would NOT amount to tipping off under the Proceeds of Crime Act 2002?
Test yourself: pick an answer
Reveal answer & explanation
Correct answer: B) Telling a partner in her own firm, who is working on the same client, that a report has been made
Explanation
Under s333A POCA 2002, a person in the regulated sector commits tipping off by disclosing that a suspicious activity report has been made, where the disclosure is likely to prejudice any investigation that might follow. Under s333B, a disclosure to an employee, officer or partner of the same undertaking is permitted, so telling a partner in her own firm is not an offence. Telling the client's finance director, a friend at the client or the public is likely to prejudice an investigation and is tipping off.
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