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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：
(ii) Effective delegation can be achieved by assigning agreed tasks to the subordinate, ensuring that resources are allocated and by specifying expected performance levels and ensuring that they are understood. In addition, it is necessary to ensure that the subordinate has the ability and experience to undertake the tasks by maintaining frequent contact and ensuring that the subordinate has authority to do the job. Sufficient authority must be delegated to fulfil the task. This authority in turn may be specific or general; the scenario suggests that the authority of the managers and supervisors is specific. The subordinate should not refer decisions upwards, and the superior should not expect this. In addition there should be no doubts over boundaries; they must be clearly defined as to who holds what authority and who accounts to whom. Therefore there must be clarity as to departmental functions and individual authority, which is at the root of the problem at Flavours Fine Foods.

正确答案：
4 (a) Stakeholders
Definition
There are a number of definitions of a stakeholder. Freeman (1984), for example, defined a stakeholder in terms of any
organisation or person that can affect or be affected by the policies or activities of an entity. Hence stakeholding can result
from one of two directions: being able to affect and possibly influence an organisation or, conversely, being influenced by it.
Any engagement with an organisation in whom a stake is held may be voluntary or involuntary in nature.
Tutorial note: any definition of a stakeholder that identifies bi-directional influence will be equally valid.
Importance of identifying all stakeholders
Knowledge of the stakeholders in the stadium project is important for a number of reasons. This will involve surveying
stakeholders that can either affect or be affected by the building of the stadium. In some cases, stakeholders will be
bi-directional in their stakeholding (claim) upon the stadium project. Stakeholders in the stadium project include the local
government authority, the local residents, the wildlife centre, the local school and the football club’s fans.
Stakeholder identification is necessary to gain an understanding of the sources of risks and disruption. Some external
stakeholders, such as the local government authority, offer a risk to the project and knowledge of the nature of the claim made
upon the football club by the stakeholder will be important in risk assessment.
Stakeholder identification is important in terms of assessing the sources of influence over the objectives and outcomes for the
project (such as identified in the Mendelow model). In strategic analysis, stakeholder influence is assessed in terms of each
stakeholder’s power and interest, with higher power and higher interest combining to generate the highest influence. In the
case, it is likely that the fans are more influential on the club’s objectives than, say, the local wildlife centre, as they have
more economic power over the club.
It is necessary in order to identify areas of conflict and tension between stakeholders, especially relevant when it is likely that
stakeholders of influence will be in disagreement over the outcomes for the project. In this case, for example, the claims of
the football club board and the local residents are in conflict.
There is a moral case for knowledge of how decisions affect people both inside the organisation or (as is the case with the
stadium project) externally.