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ACCA AA关于洗钱的审计

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发布时间：2021-09-27 14:46

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Money laundering

The Study Guide to AAA covers the issue of money laundering separately to that of laws and regulations in A2(a)to(g).ACCA’s Code of Ethics and Conduct defines‘money laundering’as:

‘...the process by which criminals attempt to conceal the true origin and ownership of the proceeds of their criminal activity,allowing them to maintain control over the proceeds and,ultimately,providing a legitimate cover for their sources of income.’

Auditors need to be particularly careful where money laundering issues are concerned–especially for a business that is predominantly cash-based because the scope for money laundering in such businesses is wide.There are usually three stages in money laundering:

Placement–which is the introduction or‘placement’of illegal funds into a financial system.

Layering–which is where the money is passed through a large number of transactions.This is done so that it makes it difficult to trace the money to its original source.【点击免费下载>>>更多ACCA学习相关资料】

Integration–which is where the‘dirty’money becomes‘clean’as it passes back into a legitimate economy.

Money laundering offences can include:

concealing criminal property

acquiring,using or possessing criminal property

becoming involved in arrangement which is known,or suspected,of facilitating the acquisition of criminal property.

There are many countries in which money laundering is a criminal offence and,where an accountant or an auditor discovers a situation which may give rise to money laundering,the accountant or auditor must report such suspicions to a‘money laundering reporting officer’(MLRO)whose responsibility it is to report such suspicions to an enforcement agency(in the UK,this enforcement agency is the National Crime Agency(NCA)).

It is an offence to fail to report suspicions of money laundering to NCA or the MLRO as soon as practicable,and it is also an offence if the MLRO fails to pass on a report to the NCA.Where the entity is actively involved in money laundering,the signs are likely to be similar to those where there is a risk of fraud,and can include:

complex corporate structure where complexity does not seem to be warranted

transactions not in the ordinary course of business

many large cash transactions when not expected

transactions where there is a lack of information or explanations,or where explanations are unsatisfactory,or

transactions with little commercial logic taking place in the normal course of business.

Question 3(b)in the March/June 2016 P7(Int)Sample Questions(now AAA)gave candidates a scenario where they were placed in the position of audit manager.The audit senior had noted as part of their review of the cash book,a receipt of$350,000 for which the source was unclear followed by a transfer of the same amount to a bank account held in another country.When questioned,the financial controller had referred the audit senior to the business owner.Documentary evidence had been requested but had not yet been received.

This particular question did not make reference to the term‘money laundering’in the scenario or in the question requirement;the question required the candidate to evaluate the implications for the completion of the audit,recommending any further actions which should be taken by the firm.

The fact that no mention of money laundering was made either in the scenario or in the question requirements is reflective of the fact that in real life those committing money laundering will not openly admit to committing such offences.Money laundering is therefore very similar(if not identical in many ways)to fraud and,therefore,auditors should set aside any beliefs concerning the integrity and honesty of the audit client and keep a sceptical mindset where such issues are concerned.

Tipping off

The term‘tipping off’means that the MLRO discloses something that will prejudice an investigation.It is an offence to make the perpetrators of money laundering aware that the auditor has suspicions or knowledge regarding their money laundering activities or that these suspicions or knowledge have been reported.It is unnecessary for the auditor to gain all the facts,or to ascertain without a doubt,that an offence has occurred.The auditor only needs to satisfy themselves that their suspicions are reasonable,and obtain sufficient evidence to show the allegations are made in good faith.

Conclusion

Candidates attempting AA and AAA are advised to gain a sound understanding of laws and regulations,not only in the context of the Syllabus and Study Guide but also in the context of real-life situations to allow for greater application of knowledge.

Keep in mind the fact that questions in AAA will not always flag up that candidates need to consider laws and regulations;the challenging nature of AAA will mean that candidates will have to conclude for themselves that questions are testing a specific subject area of the syllabus.