参加ACCA考试需要做哪些准备，速来看看这篇文章吧！

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：
(a) Tucker’s framework
Is the decision:
Profitable? For SHC, the answer to this question is yes. Profits would potentially be substantially increased by the loss of all
of its competitors and the emergence of SHC, in the short to medium term at least, as a near monopolist.
Legal? The secrecy option poses no legal problems as it is a part of normal competitive behaviour in industries. In some
jurisdictions, legislation forbids monopolies existing in some industries but there is no indication from the case that this
restriction applies to Swan Hill Company.
Fair? The fairness of the secrecy option is a moral judgment. It is probably fair when judged from the perspective of SHC’s
shareholders but the question is the extent to which it is fair to the employees and shareholders of SHC’s competitors.
Right? Again, a question of ethical perspective. Is it right to pursue the subjugation of competitors and the domination of an
industry regardless of the consequences to competitors? The secrecy option may be of the most benefit to the local community
of Swan Hill that the company has traditionally valued.
Sustainable or environmentally sound? The case says that the sink method emits at a lower rate per unit of output than the
existing process but this has little to do with the secrecy option as the rates of emissions would apply if SHC licensed the
process. This is also an argument for the licensing option, however, as environmental emissions would be lower if other
competitors switched to the sink method as well. There may be environmental implications in decommissioning the old plant
to make way for the new sink method investment.

正确答案：
(c) Software Supply Co
Here it seems that Smith & Co has referred the provision of bespoke accounting software to an external provider – Software
Supply Co, and that a commission is being paid to Smith & Co for these referrals. It is common for audit firms to recommend
other providers to their audit clients.
This could be perceived as an objectivity and self-interest threat, as the audit firm is benefiting financially through
recommending clients to a particular provider of goods and services. However, if appropriate safeguards are in place, the
referrals and receipt of commissions can continue.
Action to be taken:
– Verification from all personnel involved with the audit of clients to whom Software Supply Co has provided a service that
they have no financial or personal interest in Software Supply Co.
– Smith & Co must ensure that:
For each client where a referral is made, full disclosure has been made to the client regarding the arrangement
Written acknowledgement that Smith & Co is to receive a referral fee should be obtained from the client.
– Procedures must be put into place to monitor the quality of goods and services provided by Software Supply Co to audit
clients.