哪些人可以报考2020年ACCA，速来看看ACCA的报考条件！

正确答案：
(c) Measures
The following measures are designed to assist in preventing professional accountants from being used for money laundering
purposes:
■ developing programmes against money laundering and terrorist financing;
■ compliance officer;
■ employee training programme;
■ customer due diligence (CDD);
■ establishing/enhancing record keeping systems for:
– all transactions; and
– the verification of clients’ identities;
■ reporting of suspicious transactions;
■ refusing to have relationships with ‘shell banks’.
Tutorial note: Only FOUR are required.
Developing programmes
■ Internal policies, procedures and controls should be established and recorded including:
– compliance management arrangements (including appointment of a compliance officer);
– an ongoing employee training programme;
– an audit function to test the system.
Compliance officer
■ Appointing a compliance officer having a suitable level of seniority and experience (e.g. one of the principals of an
accountancy firm).
■ Making alternative arrangements (e.g. appointing a deputy) when the compliance officer is going to be unavailable for
a period of time (as reports have to be made as soon as is reasonably practicable).
■ The compliance officer being made responsible for:
– receiving and assessing money laundering reports from colleagues;
– making reports to the FIU; and
– ensuring that individuals are adequately trained.
Employee training programme
■ Providing an employee training programme on:
– relevant legislation (e.g. the main money laundering offences);
– ethical guidance (e.g. ACCA’s ‘Guidance for Accountants’); and
– the firm’s procedures to forestall and prevent money laundering.
■ Establishing a culture of complying with money laundering requirements.
■ Documenting the provision of training (to demonstrate compliance).
■ Training methods may effectively include:
– attending conferences, seminars and training courses run by external organizations; and
– participating in computer based training courses.
Customer due diligence (CDD)
■ Firms should not keep anonymous accounts or accounts in obviously fictitious names.
■ Firms should verify the identity of their customers, when:
– establishing business relations;
– carrying out occasional transactions (e.g. above a designated threshold);
– there is a suspicion of money laundering or terrorist financing; or
– there is doubt about the reliability or adequacy of previously obtained customer identification data.
CDD measures should include:
■ Identifying the customer and verifying that customer’s identity using reliable, independent source documents, data or
information.
Tutorial note: Similarly identify and verify the beneficial owner.
■ Obtaining information on the purpose and intended nature of the business relationship.
■ Conducting ongoing due diligence on business relationships by scrutinising transactions to ensure that they are
consistent with the firm’s knowledge of:
– the customer;
– their business and risk profile;
– the source of funds.
Tutorial note: These requirements should apply to all new customers and existing customers on the basis of materiality and
risk.
Record keeping
■ Maintaining all client identification records together with a record of all transactions, in a full audit trail form.
■ Maintaining records of transactions (both domestic or international) in a readily retrievable form. for a period of at least
five years (to facilitate swift compliance with information requests from the competent authorities).
Tutorial note: Such records must be sufficient to permit reconstruction of individual transactions (including the
amounts and types of currency involved, if any) so as to provide, if necessary, evidence for prosecution of criminal
activity.
■ Retaining client verification records throughout the period of the relationship and for five years after termination of the
relationship.
■ Making available identification data and transaction records to domestic competent authorities upon appropriate
authority.
■ Applying ACCA’s Rules of Professional Conduct ‘Retention of books, files, working papers and other documents’.
■ Paying special attention to all complex, unusual large transactions, and all unusual patterns of transactions, which have
no apparent economic or visible lawful purpose (in accordance with ISA 240 ‘The Auditor’s Responsibility to Consider
Fraud in an Audit of Financial Statements ’).
Client identification
■ For an individual – inspecting official documents, with a photograph, establishing the client’s full name and permanent
address, e.g:
– a driving licence or passport, supported by;
– a recent utility bill.
■ For the entity – obtaining from the Registrar of Companies:
– certificate of incorporation;
– company’s registered address; and
– a list of shareholders and directors.
■ Checking the names of new clients against lists of known terrorists and other sanctions information.
■ For trusts – ascertaining:
– the nature and purpose of the trust;
– the original source of funding; and
– the identities of the trustees/controllers, principal settlers and beneficiaries.
Suspicion reporting
■ Prompt reporting of suspicions to the (FIU) in a suspicious transaction report (STR).
■ There should be no ‘de minimis’ concessions. Reporting should be irrespective of:
– the amount involved; or
– whether tax matters are involved.
Tutorial note: Attempted transactions should also be reported.
■ Enhancing confidentiality of the source of reports by:
– disclosing the compliance officer only once; and
– not naming the personnel making reports to the compliance officer.
■ Disclosing further information only if:
– legally required to do so; or
– otherwise justified, in the public interest.
Shell banks
Tutorial note: A ‘shell bank’ is a bank incorporated in a jurisdiction in which it has no physical presence and which is
unaffiliated with a regulated financial group.
■ Firms should guard against relationships with parties that permit their accounts to be used by shell banks.

正确答案：D
3,980 – 270 – 180 – 3,200 = 330 : difference 100

正确答案：
6 CERTAIN PRACTICES
Tutorial note: The answer which follows is indicative of the range of points which might be made. Other relevant material will
be given suitable credit.
(a) ‘Lowballing’
Explanation of term
‘Lowballing’ is the ‘loss-leading’ practice in which auditors compete for clients by reducing their fees for statutory audits.
Lower audit fees are then compensated by the auditor carrying out more lucrative non-audit work (e.g. consultancy and tax
advice). Audits may even be offered for free.
Such ‘predatory pricing’ may undercut an incumbent auditor to secure an appointment into which higher price consultancy
services may be sold.
Ethical risks
There is a risk of incompetence if the non-audit work does not materialise and the lowballing firm comes under pressure to
cut corners or resort to irregular practices (e.g. the falsification of audit working papers) in order to ‘keep within budget’.
However, a lack of audit quality may only be discovered if the situation arises that the company collapses and the auditors
are charged with negligence.
If, rather than comprise the quality of the audit, an audit firm substantially increases audit fees, a fee dispute could arise. In
this case the client might refuse to pay the higher fee. It could be difficult then for the firm to take the matter to arbitration
if the client was misled. Thus an advocacy threat may arise.
Financial dependence is a direct incentive that threatens independence. A self-interest threat therefore arises when, having
secured the audit, the audit firm needs the client to retain its services in order to recoup any losses initially incurred.
The provision of many other services gives rise to a self-review threat (as well as a self-interest threat).
Sufficiency of current ethical guidance
In current ethical guidance, the fact that an accountancy firm quotes a lower fee than other tendering firms is not improper,
providing that the prospective client is not misled about:
– the precise range of services that the quoted fee is intended to cover; and
– the likely level of fees for any other work undertaken.
This is clearly insufficient to prevent the practice of lowballing.
Legal prohibitions on the provision of many non-audit services (e.g. bookkeeping, financial information systems design and
implementation, valuation services, actuarial services, internal audit (outsourced), human resource services for executive
positions, investment and legal services) should make lowballing a riskier pricing strategy. This may curb the tendency to
lowball.
Lowballing could be eliminated if, for example, auditors were required to act ‘exclusively as auditors’. Although regulatory
environments have moved towards this there is not a total prohibition on non-audit services.