Money Laundering: how end relationship without tipping off

Came across this scenario in Q7.11 of Osborne PETH workbook.
Accountant has to report to MLRO and also tell client he canno longer work for her. But can't say why as that could be "tipping off"

Having just raised the issue with her of not declaring all income and her refusing to change it, wouldn't it be obvious to her why he is no longer able to act for her?

How can you tell a client you are no longer able to act for them without tipping them off?


  • Bertie
    Bertie Registered Posts: 376
    You don't tell them that you've reported them.

    If a client does not comply to the status quo, you disengage.

    You obviously never, ever say that you've reported them.

    Creative licence is usually used in disengagement with someone who is more than colourful.

    For those who aren't category A offenders, put your prices up.

    Works a treat.

  • Uncleboobot
    Uncleboobot Registered Posts: 44 Regular contributor ⭐ 😼 ⭐
    edited October 2017
    To answer this question, it is important to remember that advising HMRC that you are no longer acting for a certain individual/business etc is not tipping off. There are numerous legitimate reasons why a member might stop acting for a business and it would be wrong to presume that (the discovery of) criminal activity is the only reason that members terminate their relationship with their clients/employers.

    I struggled with this question to begin with but I learned that tipping off occurs when you notify the client that a Suspicious Activity Report has been made ( with the NCA). This is different to simply notifying the client and HMRC that you are terminating the business relationship.
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