Ethics Flashcards
(99 cards)
1
Q
What is a professional?
A
professionals have specialised skills and knowledge which is maintained through CPD. They tend to belong to a professional body that enforces a code of ethics.
They have strong duties to clients and the public as well as significant power to impact clients and the public. And their effective working relationships with clients are dependent on client trust.
2
Q
What is the purpose of the RICS Rules of Conduct?
A
The RICS Rules of Conduct support positive change in the built and natural environments, through promoting and enforcing the highest ethical standards in the valuation, development and management of land, real estate, construction, and infrastructure.
3
Q
What principles are the RICS Rules of Conduct based on?
A
- Honesty
- Integrity
3.Competence - Service
5.Respect - Responsibility
4
Q
What is surveying?
A
securing the optimal use of land and its associated resources to meet social and economic needs.’
5
Q
Who needs to comply with the Rules of Conduct?
A
The Rules of Conduct apply to all members (as defined in Bye-Law 5.1) and firms regulated by RICS.
References to firms mean firms regulated by RICS.
References to the client mean anyone to whom a member or firm has agreed to provide a professional service.
RICS members and firms operate around the world, and the Rules of Conduct apply to members and firms wherever they work or practice. We recognise that laws differ between jurisdictions and that firms and members must consider the legal obligations that apply to them.
6
Q
What are the five rules of conduct?
A
- Members and firms must be honest, act with integrity and comply with their professional obligations, including obligations to RICS.
2.Members and firms must maintain their professional competence and ensure that services are provided by competent individuals who have the necessary expertise.
- Members and firms must provide good-quality and diligent service.
- Members and firms must treat others with respect and encourage diversity and inclusion.
- Members and firms must act in the public interest, take responsibility for their actions and act to prevent harm and maintain public confidence in the profession.
7
Q
What is a conflict of interest?
A
It is a situation where your duty to someone is potentially compromised by the fact that you have a material interest at stake in the matter.
There is doubt about your ability to make an impartial decision.
8
Q
What are the three types of conflicts of interest as defined by the RICS?
A
Party conflict
Own interest conflict
Confidential information conflict
9
Q
What is a party conflict?
A
When your duty to act in the interests of one client could conflict with your duty to the other client.
10
Q
What is an own interest conflict?
A
A situation in which the duty of an RICS member or a regulated firm to act in the interests of a client in a professional assignment conflicts with the interests of that same RICS member/firm (or in the case of a regulated firm, the interests of any of the individuals within that regulated firm who are involved directly or indirectly in that or any related professional assignment).
Even if you believe you are acting impartially, the conflict of interest casts doubts on this.
11
Q
What is a confidential information conflict?
A
A conflict between the duty of an RICS member (working independently or within a non-regulated firm or within a regulated firm) under paragraph 2.2 to provide material information to one client, and the duty of that RICS member (working independently or within a non-regulated firm) or of a regulated firm under paragraph 2.1 to another client to keep that same information confidential.
12
Q
How do you check for conflicts of interest?
A
Need to consider if there is an actual, potential or perceived COI on receipt of an instruction.
Examples: Database checks, advisory emails to staff to enquire about individual involvement, existing record searches, consider if there’s any personal conflicts.
Need to consider COI’s throughout the lifetime of an assignment as they can arise at any time.
13
Q
Tell me about the RICS professional standard ‘Conflicts of Interest’ (reissued 2023)
A
Main principle: A member must not advise or represent a client where doing so would represent a COI or significant risk of COI, unless informed consent has been received.
Split into three sections: 1. Sets out definitions of conflicts of interest and RICS mandatory rules, 2. General commentary notes- sets out how to apply the standard, 3. Supporting notes on how to meet the obligations in part 1 e.g. record keeping, informed consent, information barriers
Appendix A: Sample consent form
*Applies to all areas of RICS practice and geographies
14
Q
Can you proceed with an instruction if there is a conflict of interest?
A
Only with informed consent from all those who may be affected and only if it is a) in the interests of all those affected, b) it is not prohibited by law and c) will not prevent the member providing good quality service.
Must keep records of decision making
15
Q
Why is it important to avoid conflicts of interest?
A
To prevent anything
getting in the way of your duty to advise and represent each client objectively and independently so that clients & in turn the public can be confident in your work/advice.
16
Q
What is informed consent?
A
Can be given in writing by the party if the surveyor is transparent about the nature of the conflict, any material factors, how it will be dealt with (e.g. information/ethical barrier) and ensures the affected party understands what they are doing if they choose to proceed.
Should only be sought if all relevant parties are best served by doing so and must be provided in writing
17
Q
If you proceed with a conflict of interest what things must be in place?
A
Robust information/ethical barriers between those acting for respective clients
e.g. surveyors must be different and physically separated; virtual IT barrier; all information securely stored; clear audit trail
18
Q
What are terms of engagement?
A
a written record of the agreement between a client and a firm (or two parties) to ensure clarity of the scope of works, fee basis etc. Designed to minimise future conflict/confusion.
19
Q
What must you do before accepting an instruction? (4)
A
- Check professional competence
- Check there are no conflicts of interest or personal interests
- Confirm terms of engagement in writing and get written approval from the client before starting work on an instruction
- Customer Due diligence
20
Q
When was RICS founded?
A
1868
21
Q
What’s included in terms of engagement?
A
- Name of client and competent surveyor
-Conflict of Interest declaration if relevant - Scope of works/instruction
-Assumptions - Proposed fee basis & payment of expenses (and on what basis this is calculated)
- Complaints Handling procedure
-How client data will be used
-Limitations in liability (at a maximum should be the PII cover limit)
22
Q
When did RICS receive its Royal Charter?
A
1881
23
Q
What are the different levels of RICS membership?
A
- FRICS
- MRICS
- AssocRICS
- Trainee/Student
c.140,000 qualified and trainee members
24
Q
What do you need to provide to become a Fellow?
A
Evidence of four fellowship characteristics, which includes 5+ years at MRICS, leadership role, professional achievement, academic achievement or raising profile of the RICS.
Also portfolio & compliant CPD record
25
What is the role of the RICS?
The RICS promotes and enforces the highest professional qualifications and standards in the development and management of land, real estate, construction and infrastructure (RICS, 2020)
- It is accountable to members and the public
- Involved in policy influence and political engagement
26
What was the outcome of the Bichard Review?
The Bichard Review was commissioned due to internal governance failings reported in 2021, it included consultation with members and external stakeholders
Main recommendations:
- Increased focus on public interest, including amending Royal Charter and creating a public interest panel
- Maintaining self-regulation, via greater independence for regulatory functions
- Increased focus on D&I
- Greater support for regional boards, increasing member engagement
- Independent review of RICS governance
- New, simpler and accountable governance structure
- Renewed emphasis on key issues such as sustainability and climate change
27
What are the 5 Future Foundations?
- Vision (a natural and built environment that is sustainable, resilient and inclusive for all)
- Mission (inspire members, advance knowledge, uphold standards)
- Strategic Goals (sustainability, diverse next gen, trust, member engagement)
- Values (professional, collaborative, inclusive, ambitious)
- A world class organisation
28
What are the benefits of being an RICS member?
- Status
- Recognition
- Market advantage
- Knowledge
- Network
29
What are the eligibility requirements for registration?
Firms providing surveying services to the public must register for regulation to ensure there is a recognised quality benchmark for all firms.
- Must have RICS members, 50% mandatory regulation, 25% can apply for regulation
- Must make an annual return to RICS confirming compliance with obligations
- Must nominate a 'Responsible Principal' who must ensure all reasonable steps are taken and systems in place to ensure compliance
- Disputes around this are heard by the RICS Standards & Regulations Board
30
What steps do you need to take to set up your own RICS regulated firm?
- Inform the RICS by submitting the Firm Details Form on RICS website (e.g. type of business, staff, clients)
-Appoint a responsible Principal (who ensures the firm complies with RICS standards and regulations/engages with RICS)
-Register with RICS for regulation of the firm
-Set up PII and send details to RICS
- Obtain RICS approval for complaints handling procedure (includes ADR mechanism e.g. The Property Ombudsman (TPO) or Centre for Effective Dispute Resolution (CEDR)
- Set up complaints log
- Appoint complaints handling officer
- Client money handling procedure, including protection scheme (client gets interest)
- RICS logo and designations- ensure all business literature contains it
-Locum agreement (another professional who will cover your work if you are unable to do so)
-CPD logged and staff training
- RICS annual return completion
31
What are members and firms 'professional obligations' as set out in Appendix A of the Rules of Conduct?
1. Comply with CPD requirements
2. Cooperate with RICS
3. Provide all information reasonably requested by the Standards & Regulation Board
Firms must also:
1. Have a published complaints handling procedure, including an ADR provider approved by RICS and maintain complaints log
2. PII
3. A designation on business literature that they are regulated by RICS
4. Report to RICS any matters that require reporting
32
Why were the RICS rules of conduct updated?
To reflect evolving industry practices, including sustainability, diversity and inclusion, and the use of technology.
Aims to provide a simpler and clearer framework for members and the public to understand ethical expectations within the profession.
To better align with the modern landscape of the built environment.
33
What are members CPD obligations?
Minimum 20 hours CPD each year, at least 10 hours must be formal
Must maintain good understanding of the RICS Rules of Conduct during a rolling three year period
Must record CPD by 31st Jan each year
APC candidates- Minimum 48 hours every 12 months. At least 50% must be formal.
34
What is the RICS Decision Tree?
Provides a framework of questions which members should ask themselves when facing a situation in which they are asked to act in a potentially unethical manner or situation
- It encourages considering legality, morality and consistency with the Rules of Conduct
35
Who can you contact if you're facing an ethical issue?
RICS Regulation Confidential Hotline
36
Examples of RICS Decision tree questions?
Is it legal?
Do you have sufficient facts on the issue?
Is it line with the Rules of Conduct?
Would you be happy for your actions to be made public?
37
What are the three levels of disciplinary action?
1. Action by Head of Regulation (formal investigation)
2. Disciplinary Panel (drawn from the independent Regulatory Tribunal)
3. Appeal Panel
38
What different options can happen following the Head of Regulation's formal investigation?
1. Fixed penalty notice- used for breaches of the rules relating only to supply of information to the RICS. Either a fine and/or a caution
2.Regulatory Compliance Order
- For low level breaches of the Rules that can be easily corrected
- Written doc stating what the member/firm needs to do and agreement to pay fine e.g. not doing appropriate CPD
3. Action by Disciplinary Panel
- Used for more serious breaches of conduct
- Hearing may be required
- Membership of panel includes non-RICS members
- Penalties include: Regulatory compliance order, reprimand, fine, unlimited amount of fine per breach, conditions on future continued RICS registration, expulsion from membership/remove firm, publication of results
*Note- personal social media use can be included e.g. bullying and harrassment
39
Talk me through the different types of RICS documentation
Professional standards are replacing professional statements and guidance notes- RICS in the process or reviewing and recategorising all docs to become professional standards
A) Professional standard- includes mandatory requirements 'must do' and best practice 'should do'
B) Practice information
- SUpports the practice, knowledge and performance of RICS members and firms
- Contains good practice, information, processes and advice
C) Practice Alerts
- Web page on RICS to collect practice alerts
Acts as tool for warning profession to emerging areas of risk e.g. sustainability, AI, commercial property management and FRAs
40
How long should you keep old files for as a minimum?
Minimum 6 years before disposal and destroyed securely
41
What are the key requirements for a complaints handling procedure?
- Requirement for RICS regulated firms to have a published CHP that meets the Rules of Conduct
-Must make clear to clients that you have a CHP in terms of engagement/terms of business
-Must notify PII insurers as soon as you're made aware of a complaint as could lead to a claim for negligence
-Complaints log must be maintained
-Firms must have an RICS approved Alternative Dispute Resolution (ADR) mechanism in the CHP
42
How should you deal with a complaint?
Stage 1 (In House)
-Details of the CHP should be shared with the complainant
-Details of the Complaints Handling Officer must be stated as the person to contact
-Complaint must be made in writing
-Complaint must be acknowledged within 7 days and investigated within 28 days
Stage 2 (ADR- Third party resolution)
- If the complainant is unhappy with the review, an independent redress scheme can be used
- E.g. Centre for Effective Dispute Resolution (CEDR), The Property Redress Scheme and the RICS Dispute Resolution Service
43
What is formal CPD?
All structured learning with clear learning objectives and outcomes
e.g. structured online training, courses, seminars, self-managed learning assessed by expert 3rd party
44
What is informal CPD
Any self managed learning relevant or related to your professional role
e.g. private study, on the job training, informal seminars/events
There is an RICS Decision Tree to decide if CPD is formal or informal.
45
What is duty of care?
Duty of care exists to clients and third parties, using 'reasonable care and skill
46
What needs to happen for a negligence claim to be made?
1.Duty of care to be breached
2. Loss
3. Damages
= negligence claim
47
Under the Limitation Act (1980) where are the current limitation periods (time limits) for negligence?
Summary: Generally it's 6 years from the date of the breach to bring claims for negligence
Contract breaches- 6 years from the date of the negligent act, breach of contract or emission.
Section 14A provides alternative limitation period of 3 years from the date of knowledge of the damage, subject to 15 years long stop from the negligent act (e.g. personal injury)
Tort breaches- 6 years from the date the claimant suffered the loss
48
How to avoid/reduce negligence claims?
- Clearly understand client objectives
- Agree terms of engagement
- Ensure you are competent to undertake instruction
- Act in accordance with RICS advice
- Make detailed file notes (timestamped) and take photographs
- Keep up to date with market knowledge/legislation/record CPD
- Cap the professional liability excess on your PII policy in the terms of engagement
49
What is professional indemnity insurance?
- Mandatory for surveyors working in practice
- Protects clients, surveyors and 3rd parties against negligence claims when there is a duty of care breached and claims for damages arises
- Members must ensure adequate and appropriate level of insurance is in place for each instruction with consideration of potential liabilities
- All policies must be underwritten by RICS approved insurer, can be found on RICS website
- PII certificate must be sent to RICS annually
- Early notification to insurers required when potential claim arises
50
What are the minimum PII requirements for each claim based on turnover of the firm?
Firm turnover in preceding year:
Under 100k turnover- £250k
100-200k turnover- £500k
200k+ - 1 million
51
What are the maximum levels of uninsured excess required by RICS for PII?
Up to 10 million- the greater of 2.5% of the sum insured or 10,000
Over 10 million- no set limit
52
Which claims does PII protect you against?
Any claims made during the lifetime of the policy, regardless of the date the negligent act took place, also known as 'claims made basis'
53
What is run off cover, how much is needed and for how long ?
'Adequate and appropriate' run off cover required following cessation of trading.
Required for a minimum of 6 years.
Consumer claims- 1 million over 6 years
54
How does a liability cap work?
Manages the risks associated with professional work. Most firms cap their liability for individual instructions- limits financial exposure.
Must declare any liability cap in terms of engagement so client is aware.
55
Is PII required if you work pro-bono?
Yes
56
What guidance is there on PII?
Members Support Service- useful if the employer has gone into administration
RICS Practice Info- Risk, Liability and Insurance (2021)
RICS Regulation Document- Professional Indemnity Insurance Requirements (2024)
57
What are the 6 areas of good practice set out in the RICS professional standard 'Client Money Handling' (2019)?
1. Holding client money
2. Providing information to clients
3. Receipts of client money
4. Payments from client accounts
5. Accounting records and controls
6. Compliance
58
What are some of the procedures for handling client's money?
- Client accounts must be kept separate and identifiable
- The word client must be on the bank account and cheque book
-Client must be able to have monies on demand
- Accurate records with running balance available
- Regular bank reconciliation
-Annual audit and reporting obligations by qualified accountant employed by RICS
-Records of all cash transactions
- Money can only be withdrawn if required
- RICS can inspect on 3 yearly routine basis by an RICS accountant
- Must display procedures document on website for handling client money
59
What is the last resort if an RICS regulated firm is unable to repay a client's money?
RICS run a Client Money Protection scheme for claims from clients, provides a last resort
60
What must you do when setting up your own firm to comply with RICS?
-Inform RICS by completing a Firm Details Form
-Appoint a Responsible Principal for all RICS communication
-Register with RICS for regulation of the firm
-Arrange PII and send details to RICS
-Arrange other insurances e.g. building/contents/public liability/employers liability
-Set up procedures for client money handling and protection
-Obtain RICS approval for complaints handling procedure
-Set up complaints log
-Appoint a Complaints Handling Officer
-Use RICS logo kit 'Regulated by RICS'
-Ensure CPD logged online and set up staff training plan
-Complete RICS annual return
61
What must you do when setting up your own firm to comply with statute?
-Disclose business name
-Equality Act 2010 compliance
-Financial Service compliance
-Bribery Act 2010 compliance
-Appoint money laundering officer
-H&S compliance
-Asbestos Register
-Register for data protection
-Estate Agency compliance
-Inform HMRC for AT and Tax registration
-Compliance with current employment law e.g. national living wage, working hours, pensions, gender pay gap reporting etc.
- Insurance compliance for employer and public liability
62
What must you do when closing an RICS practice?
-Inform RICS of your retirement/closure and deregister
-Inform clients and hand over arrangements made to a new firm
-Return client monies
-Inform insurers
-Procure PII run off cover for minimum of 6 years from expiry of policy in place at the time of cessation
-Retain copy of client files and records for minimum 6 years
63
What is the purpose of the Bribery Act (2010)?
To reduce bribery in business in UK and abroad
64
What is a bribe?
The giving, offering, promising or receiving of an advantage such as a payment, gift or service for an action which is illegal or a breach of trust
65
What is a gift?
Something given willingly to someone as a present, with no expectation of anything in return
66
Difference between a bribe and a gift?
Intention- what are they trying to get out of it giving that item
Context
A gift is proportionate and reasonable, given openly/transparently, of low value. A bribe is given secretively, given with the intent of gaining an advantage. Higher in value/inappropriate to the context. Suspicious timing.
67
What are the 6 principles of the bribery act?
1. P-roportionality
2. T-op level commitment
3. R- isk assessment
4. D-ue diligence
5. C-ommunication
6. M-onitoring and review
68
What are the four offences set out in the Bribery Act 2010?
1. Bribing
2. Receiving a bribe
3. Bribing a foreign public official
4. Failing to prevent bribery
69
What is not considered a bribe?
Hospitality, promotional or other 'low value' business expenditure which aims to improve the image of a firm is acceptable
70
Are tickets to a sporting event or client meals considered an offence under the Bribery Act?
So long as it is reasonable and proportionate this would not constitute an offence but it must be accurately recorded on the gift hospitality register
71
Are employers responsible for an employee's corrupt acts?
Yes, unless they can show they had adequate policies and procedures in place to combat bribery, such as training, reviews, clear policies and risk management
72
What is the penalty for bribery?
- Policed by the Serious Fraud Office
- Maximum penalty of 10 years in prison and/or an unlimited fine
73
What is money laundering?
When proceeds of criminal activities are disguised or converted to legitimate assets
74
What are the key provisions of the Terrorist Financing and Transfer of Funds Regulations (2017)?
1. Must have a written money laundering and terrorist financing risk assessment
2. Must have systems, policies, controls and procedures to address money laundering/terrorist financing
3. Appropriate internal controls
4. Staff training
5. Comply with new customer, enhanced and simplified due diligence requirements
6. Comply with requirements relating to politically exposed persons (PEPs)
7. Appropriate record keeping, policies and procedures
8.AML checks to confirm identity of proposed purchaser of a property and source of funds before exchanging contracts
8. Consider additional risks e.g. transactions between parties in high risk countries
75
What are red flags for money laundering?
- Complex or unusually large transactions
- Unusual patterns of transactions
- Transactions without economic/legal purpose
- Inability/unwillingness to provide identity documents
- Changes to parties involved in transactions
- Payment of fees/purchase/rent in unusual currencies
- Unexpected urgency
76
What are the levels of due diligence checks?
CDD- Customer Due Diligence
EDD- Enhanced due diligence
77
How do you complete a customer due diligence check?
- ID check e.g. passport, driving licence
- Identify the managing agent/beneficial owners
- Info on the purpose and intended nature of business relationship
- Info on funding arrangements- e.g. bank statement
-Confirm the name, company number and address of registered office (for a company)
-C0nfirm names of directors unless listed on a regulated market e.g. London Stock Exchange (for a company)
78
What is enhanced due diligence?
Additional procedures required for a transaction or business relationship involving someone in a 'high risk 3rd country' or a 'politically exposed person' (PEP)/family member/business associate
-It required additional evidence and monitoring/examination of purpose of the transaction
-PEP is normally higher risk for involvement in bribery and corruption due to their power and influence
79
Give examples of a PEP
Government Officials
Diplomats
Senior political party officials
80
What is the cash limit that you can accept for a payment?
10,000 euros
81
What should you do if you suspect money laundering?
Report to the Money Laundering Reporting Officer who must file a Suspicious Activity Report (SAR) to the National Crime Agency
82
What should you do if you find any discrepancies between your data and Companies House?
Report this to Companies House and maintain records for minimum 5y
83
What are the penalties for money laundering?
Max 14 years prison & unlimited fine for assisting with ML
Max 5 years in prison & unlimited fine for tipping someone off that they are under suspicion/ OR for FAILING TO REPORT money laundering
84
What are typical checks for money laundering?
Private individuals
-Copy of passport or driving licence
-Copy of bank statement, credit card bill, council tax statement etc. to show evidence of address, not more than 3 months old
Private Limited Company
- Full name, registered number, registered office, business address, names of directors and shareholders with 25%+ holding
- Identify higher risk clients
85
What are the different sections of the RICS professional standard on bribery, corruption, money laundering and terrorist financing?
Part 1: Mandatory requirements in relation to B&C (bribery and corruption) e.g. not offer/accept a bribe, report suspicion, have procedures in place that complies with the law.
Also ML&TF- not facilitate/be complicit in ML and TF, have appropriate systems in place, report suspicion, evaluate and review risks, verify client, retain records
Part 2: Guidance setting out good practice e.g. gifts register, written policy, code of behaviour
Part 3: Supplementary guidance on concepts in pt 1 and 2- e.g. establishing a risks based approach- who/what/why & dealing with PEPs
86
What are the proposed changes to the Countering Bribery & Coruption, Money Laundering and Terrorist Financing standard?
Being reviewed and updated to address the evolving landscape of financial crimes, including issues driven by the rise of new technologies such as artificial intelligence (AI) and the increasing use of digital currency.
It also incorporates the latest developments in global trade, including the growing utilisation of natural resources such as gold and timber for trade-based money laundering.
87
What advice does the RICS Practice Information 'Risk, Liability and Insurance' (2021) give?
- Use liability caps to manage risks
- Be aware of third party reliance- make it explicit that advice can only be relied on by the client named in the terms of engagement in any reports etc.
88
What are estate agents' legal obligations in relation to money laundering?
- Letting agents must register with HMRC if they let individual properties for more than 10,000 euros/month
-CDD checks on vendors/purchasers, landlords/tenants
-EDD checks if red flags occur
-Policies to scrutinise suspicious transactions
89
What are the three main areas of offence under the Proceeds of Crime Act 2002?
1. Concealing criminal property
2. Arrangements- entering into an arrangement which facilitates use/control of criminal property
3. Acquisition use and possession- if a person acquires, uses or has possession of criminal property
90
What is fraud?
Any activity that relies on deception to receive a gain
| Becomes a crime when it is a knowing misrepresentation of the truth
91
Who polices the Bribery Act 2010?
The Serious Fraud Office
92
Who is RICS CEO?
Justin Young
93
Who is RICS President?
Justin Sullivan
94
Who is RICS President elect and why?
Nicholas Maclean (JS referred himself to the RICS Standards and Regulation Board, requesting an independent regulatory review into High Court judgement on moth infested mansion)
95
What is your organisation's policy on hospitality and gifts?
Must record any gifts or hospitality (given or received) over the value of £5 on the gift register regardless of whether it is accepted.
Must get authorisation from manager to accept a gift over £5- and general principle is that you shouldn't unless it would cause offence to refuse
May accept hospitality (refreshments & food) at operational meetings or conferences if it is reasonable and proportionate. Anything else (meals at a restaurant, sport tickets etc) must be politely refused
96
What is your organisation's complaints handling procedure?
-Details of the policy available online on gov.uk website
-Must make the complaint in writing to the relevant complaints handling officer (different ones for different DWP services e.g. Access to work, Jobcentre Plus, or the general DWP Complaints)
-Acknowledge within 7 days and respond within 28 days
-If unhappy with response can request it's sent to the senior manager. Complaints team will be in contact within 15 days to discuss
-Final response by telephone or letter
-If still unhappy, refer to the Independent Case Examiner (ICE) within 6 months of receiving the final response
97
What is the structure of the RICS?
Privy Council sits at the top (grants and awards Royal Charter)
Then the Governing Council
Underneath the Governing Council is the Standards and Regulations Board, Regulatory Tribunal and Management Board.
Below that are the world regional boards and finance committee
98
What should you do if you suspect your client of terrorism?
Can't alert the client, this would be considered tipping off under anti-terrorism legislation
I would report to my firm's Anti Money Laundering Reporting Officer, as well as my manager.
File suspicious activity report to the National Crime Agency
Cease any further contact with the client until cleared
99
What should you do if you suspect a colleague/manager of bribery?
If it was my manager, I couldn't speak to them directly because it would be considered tipping off
Would raise my concerns through my organisation's whistleblowing procedure/speak to internal HR team.
Depending on the scale of the bribery, I could escalate externally to National Crime Agency, the Police, or the Serious Fraud Office.
