(c) Your firm has provided financial advice to the Pholey family for many years and this h

Question

(c) Your firm has provided financial advice to the Pholey family for many years and this has sometimes involved your

firm in carrying out transactions on their behalf. The eldest son, Esau, is to take up a position as a senior

government official to a foreign country next month. (4 marks)

Required:

Identify and comment on the ethical and other professional issues raised by each of these matters and state what

action, if any, Dedza should now take.

NOTE: The mark allocation is shown against each of the three situations

Answer 1

正确答案：
(c) Financial advisor
■ Customer due diligence (CDD) and record-keeping measures apply to designated non-financial businesses and
professions (such as Dedza) who prepare for or carry out certain transactions on behalf of their clients.
■ Esau is a ‘politically exposed person’ (‘PEP’) (i.e. an individual who is to be entrusted with prominent public functions
in a foreign country).
■ Dedza’s business relationships with Pholey therefore involve reputational risks similar to those with Esau. In addition
to performing normal due diligence measures Dedza should:
? have risk management systems to have determined that Esau is a PEP;
? obtain senior partner approval for maintaining business relationships with such customers;
? take reasonable measures to establish the source of wealth and source of funds;
? conduct enhanced ongoing monitoring of the business relationship.
■ Dedza can choose to decline to act for Pholey and/or Esau (if asked).
■ If the business relationship is to be continued senior partner approval should be obtained for any transactions carried
out on Pholey’s behalf in future.
Tutorial note: The Pholey family is not described as an audit client therefore no familiarity threat arises in relation to an
audit (the family may not have any involvement in entities requiring an audit).