(c) The OECD’s Financial Action Task Force on Money Laundering (FATF) recommends preventative measures to betaken by independent legal professionals and accountants (including sole practitioners, partners and employedprofessionals within professional firm

正确答案：
5 BARTOLOME
(a) Senior audit staff leaving for employment with client
Ethical and professional issues
■ Leon’s independence is in doubt as he is threatened by self-interest. Leon’s objectivity in relation to the audit may be
influenced by a desire to please and impress Moreno, as a prospective employer.
■ There appears to be a lack of integrity on the part of James and/or Leon:
? Leon should have confided in an appropriately senior manager/partner of Bartolome. In not doing so he has
compromised the firm by having applied for a position with a client whilst assigned to the client.
? James may lack integrity in having advised Bartolome of the short-listing if he gave an undertaking to Leon not to
do so. (Conversely, James may be acting with integrity in advising Bartolome and as a matter of professional
courtesy.)
■ Leon should be removed from the audit assignment immediately regardless of whether or not he is finally appointed by
Moreno.
■ Leon should be given an oral warning (assuming this to be a first offence) for failing to adhere to Bartolome’s quality
control policies and procedures (requiring disclosure to the firm of any threat of involvement with an audit client).
■ The working papers for all interim audit work relating to Moreno performed under the supervision of Leon should be
reviewed as soon as possible, before the balance sheet date (at the end of the month).
Implications for continuation with assignment
The assignment can be properly continued with a new senior in charge of the audit of the financial statements for the year
ending 30 June 2005. Any planning of the year end and final audit work by Leon should be reviewed, amended as necessary
and approved before any further work is undertaken.

正确答案：
(b) Need for ethical guidance
■ Accountants (firms and individuals) working in a country that criminalises money laundering are required to comply with
anti-money laundering legislation and failure to do so can lead to severe penalties. Guidance is needed because:
– legal requirements are onerous;
– money laundering is widely defined; and
– accountants may otherwise be used, unwittingly, to launder criminal funds.
■ Accountants need ethical guidance on matters where there is conflict between legal responsibilities and professional
responsibilities. In particular, professional accountants are bound by a duty of confidentiality to their clients. Guidance
is needed to explain:
– how statutory provisions give protection against criminal action for members in respect of their confidentiality
requirements;
– when client confidentiality over-ride provisions are available.
■ Further guidance is needed to explain the interaction between accountants’ responsibilities to report money laundering
offences and other reporting responsibilities, for example:
– reporting to regulators;
– auditor’s reports on financial statements (ISA 700);
– reports to those charged with governance (ISA 260);
– reporting misconduct by members of the same body.
■ Professional accountants are required to communicate with each other when there is a change in professional
appointment (i.e. ‘professional etiquette’). Additional ethical guidance is needed on how to respond to a ‘clearance’ letter
where a report of suspicion has been made (or is being contemplated) in respect of the client in question.
Tutorial note: Although the term ‘professional clearance’ is widely used, remember that there is no ‘clearance’ that the
incumbent accountant can give or withhold.
■ Ethical guidance is needed to make accountants working in countries that do not criminalise money laundering aware
of how anti-money laundering legislation may nevertheless affect them. Such accountants may commit an offence if,
for example, they conduct limited assignments or have meetings in a country having anti-money laundering legislation
(e.g. UK, Ireland, Singapore, Australia and the United States).

正确答案：
6 DEVELOPMENTS AND CERTIFIED CHARTERED ACCOUNTANTS
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) IFAC’s ‘Code of Ethics for Professional Accountants’
Since its issue in 1996, IFAC’s ‘Code of Ethics for Professional Accountants’ (‘The Code’) has undergone several revisions
(1996, 1998, 2001, 2004 and 2005). IFAC holds the view that due to national differences (of culture, language, legal and
social systems) the task of preparing detailed ethical requirements is primarily that of the member bodies in each country
concerned (and that they also have the responsibility to implement and enforce such requirements).
In recognizing the responsibilities of the accountancy profession, IFAC considers its own role to be in providing guidance and
promoting harmonization. IFAC has established ‘The Code’ to provide a basis on which the ethical requirements for
professional accountants in each country should be founded.
IFAC’s conceptual approach is principles-based. It provides a route to convergence that emphasises the profession’s integrity.
This approach may be summarised as:
■ identifying and evaluating circumstances and relationships that create threats (e.g. to independence); and
■ taking appropriate action to:
– eliminate these threats; or
– reduce them to an acceptable level by the application of safeguards.
If no safeguards are available to reduce a threat to an acceptable level an assurance engagement must be refused or
discontinued.
This approach was first introduced to Section 8 of The Code, on independence, and is applicable to assurance engagements
when the assurance report is dated on or after 31 December 2004.
Further to the cases of Enron, Worldcom and Parmalat, IFAC issued a revised Code in July 2005 that applies to all professional
accountants, whether in public practice, business, industry or government2.
A member body of IFAC may not apply less stringent standards than those stated in the Code. The Code is effective from
30 June 2006.
Practicing accountants and members in business must maintain the high standards of professional ethics that are expected
by their professional bodies (such as ACCA). These developments codify current best practice in the wake of the
aforementioned recent corporate scandals.
The developments in The Code have wider application in that it:
■ applies to all assurance services (not just audit);
■ considers the standpoints of the firm and of the assurance team.
Since ACCA is a member-body of IFAC the elevation of The Code to a standard will affect all Chartered Certified Accountants.
.

正确答案：
(d) Professional accountant’s liability
Liability for reporting on PFI
Independent accountants may be required to report on PFI for many reasons (e.g. to help secure a bank loan). Such forecasts
and projections are inherently unreliable. If the forecast or projection does not materialise, and the client or lenders (or
investors) consequently sustain financial loss, the accountant may face lawsuits claiming financial loss.
Courts in different jurisdictions use various criteria to define the group of persons to whom independent accountants may be
held liable for providing a report on an inaccurate forecast or projection. The most common of these are that an accountant
is liable to persons with whom there is proximity:
(i) only (i.e. the client who engaged the independent accountant);
(ii) or whose relationship with the accountant sufficiently approaches privity;
(iii) and to persons or members of a limited group of persons for whose benefit and guidance the accountant supplied the
information or knew that the recipient of the information intended to supply it;
(iv) and to persons who reasonably can be foreseen to rely on the information.
Measures to reduce liability
As significant assumptions will be essential to a reader’s understanding of a financial forecast, the independent accountant
should ensure that they are adequately disclosed and clearly stated to be the management’s responsibility. Hypothetical
assumptions should be clearly distinguished from best estimates.
The introduction to any forecast (and/or report thereon) should include a caveat that the prospective results may not be
attained. Specific and extensive warnings (‘the actual results … will vary’) and disclaimers (‘we do not express an opinion’)
may be effective in protecting an independent accountant sued for inaccuracies in forecasts or projections that they have
reported on.
Any report to a third party should state:
■ for whom it is prepared, who is entitled to rely on it (if anyone) and for what purpose;
■ that the engagement was undertaken in accordance with the engagement terms;
■ the work performed and the findings.
An independent accountant’s report should avoid inappropriate and open-ended wording, for example, ‘we certify …’ and ‘we
obtained all the explanations we considered necessary’.
Engagement terms to report on PFI should include an appropriate liability cap that is reasonable given the specific
circumstances of the engagement.
The independent accountant may be able to obtain indemnity from a client in respect of claims from third parties. Such ‘hold
harmless’ clauses obligate the client to indemnify the independent accountant from third party claims.

正确答案：
(c) Application of ethical principles to a fraud investigation
IFAC’s Code of Ethics for Professional Accountants applies to all ACCA members involved in professional assignments,
including forensic investigations. There are specific considerations in the application of each of the principles in providing
such a service.
Integrity
The forensic investigator is likely to deal frequently with individuals who lack integrity, are dishonest, and attempt to conceal
the true facts from the investigator. It is imperative that the investigator recognises this, and acts with impeccable integrity
throughout the whole investigation.
Objectivity
As in an audit engagement, the investigator’s objectivity must be beyond question. The report that is the outcome of the
forensic investigation must be perceived as independent, as it forms part of the legal evidence presented at court. The
investigator must adhere to the concept that the overriding objective of court proceedings is to deal with cases fairly and justly.
Any real or perceived threats to objectivity could undermine the credibility of the evidence provided by the investigator.
This issue poses a particular problem where an audit client requests its auditors to conduct a forensic investigation. In this
situation, the audit firm would be exposed to threats to objectivity in terms of advocacy, management involvement and selfreview.
The advocacy threat arises because the audit firm may feel pressured into promoting the interests and point of view
of their client, which would breach the overriding issue of objectivity in court proceedings. Secondly, the investigators could
be perceived to be involved in management decisions regarding the implications of the fraud, especially where the investigator
acts as an expert witness. It is however the self-review threat that would be the most significant threat to objectivity. The selfreview
threat arises because the investigation is likely to involve the estimation of an amount (i.e. the loss), which could be
material to the financial statements.
For the reasons outlined above, The Code states that the firm should evaluate threats and put appropriate safeguards in place,
and if safeguards cannot reduce the threats to an acceptable level, then the firm cannot provide both the audit service and
the forensic investigation.
Professional competence and due care
Forensic investigations will involve very specialist skills, which accountants are unlikely to possess without extensive training.
Such skills would include:
– Detailed knowledge of the relevant legal framework surrounding fraud,
– An understanding of how to gather specialist evidence,
– Skills in the safe custody of evidence, including maintaining a clear ‘chain’ of evidence, and
– Strong personal skills in, for example, interview techniques, presentation of material at court, and tactful dealing with
difficult and stressful situations.
It is therefore essential that forensic work is only ever undertaken by highly skilled individuals, under the direction and
supervision of an experienced fraud investigator. Any doubt over the competence of the investigation team could severely
undermine the credibility of the evidence presented at court.
Confidentiality
Normally accountants should not disclose information without the explicit consent of their client. However, during legal
proceedings arising from a fraud investigation, the court will require the investigator to reveal information discovered during
the investigation. There is an overriding requirement for the investigator to disclose all of the information deemed necessary
by the court.
Outside of the court, the investigator must ensure faultless confidentiality, especially because much of the information they
have access to will be highly sensitive.
Professional behaviour
Fraud investigations can become a matter of public interest, and much media attention is often focused on the work of the
forensic investigator. A highly professional attitude must be displayed at all times, in order to avoid damage to the reputation
of the firm, and of the profession. Any lapse in professional behaviour could also undermine the integrity of the forensic
evidence, and of the credibility of the investigator, especially when acting in the capacity of expert witness.
During legal proceedings, the forensic investigator may be involved in discussions with both sides in the court case, and here
it is essential that a courteous and considerate attitude is presented to all parties.

正确答案：
6 MONEY LAUNDERING
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) Meaning of the term
■ Money laundering is the process by which criminals attempt to conceal the true origin and ownership of the proceeds
of their criminal activity (‘dirty’ money) allowing them to maintain control over the proceeds and, ultimately, providing a
legitimate cover for their sources of income.
■ The term is widely defined to include:
– possessing; or
– in any way dealing with; or
– concealing
the proceeds of any crime (‘criminal property’).
■ It also includes:
– an attempt or conspiracy or incitement to commit such an offence; or
– aiding, abetting, counselling or procuring the commission of such an offence.
■ Further, it includes failure by an individual in a regulated sector to inform. the financial intelligence unit (FIU), as soon
as practicable, of knowledge or suspicion that another person is engaged in money laundering.
Tutorial note: The FIU serves as a national centre for receiving (and, as permitted, requesting), analysing and
disseminating suspicious transaction reports (STRs).

正确答案：
5 FOX & STEEPLE – THREE AUDIT ASSIGNMENTS
(i) Threats to independence
Self-interest
Tutorial note: This threat arises when a firm or a member of the audit team could benefit from a financial interest in, or
other self-interest conflict with, an assurance client.
■ A self-interest threat could potentially arise in respect of any (or all) of these assignments as, regardless of any fee
restrictions (e.g. per IFAC’s ‘Code of Ethics for Professional Accountants’), the auditor is remunerated by clients for
services provided.
■ This threat is likely to be greater for Huggins Co (larger/listed) and Gray Co (requires other services) than for Blythe Co
(audit a statutory necessity).
■ The self-interest threat may be greatest for Huggins Co. As a company listed on a recognised stock exchange it may
give prestige and credibility to Fox & Steeple (though this may be reciprocated). Fox & Steeple could be pressurised into
taking evasive action to avoid the loss of a listed client (e.g. concurring with an inappropriate accounting treatment).
Self-review
Tutorial note: This arises when, for example, any product or judgment of a previous engagement needs to be re-evaluated
in reaching conclusions on the audit engagement.
■ This threat is also likely to be greater for Huggins and Gray where Fox & Steeple is providing other (non-audit) services.
■ A self-review threat may be created by Fox & Steeple providing Huggins with a ‘thorough examination’ of its computerised
systems if it involves an extension of the procedures required to conduct an audit in accordance with International
Standards on Auditing (ISAs).
■ Appropriate safeguards must be put in place if Fox & Steeple assists Huggins in the performance of internal audit
activities. In particular, Fox & Steeple’s personnel must not act (or appear to act) in a capacity equivalent to a member
of Huggins’ management (e.g. reporting, in a management role, to those charged with governance).
■ Fox & Steeple may provide Gray with accounting and bookkeeping services, as Gray is not a listed entity, provided that
any self-review threat created is reduced to an acceptable level. In particular, in giving technical advice on financial
reporting, Fox & Steeple must take care not to make managerial decisions such as determining or changing journal
entries without obtaining Gray’s approval.
■ Taxation services comprise a broad range of services, including compliance, planning, provision of formal taxation
opinions and assistance in the resolution of tax disputes. Such assignments are generally not seen to create threats to
independence.
Tutorial note: It is assumed that the provision of tax services is permitted in the jurisdiction (i.e. that Fox and Steeple
are not providing such services if prohibited).
■ The due diligence reviews for Gray may create a self-review threat (e.g. on the fair valuation of net assets acquired).
However, safeguards may be available to reduce these threats to an acceptable level.
■ If staff involved in providing other services are also assigned to the audit, their work should be reviewed by more senior
staff not involved in the provision of the other services (to the extent that the other service is relevant to the audit).
■ The reporting lines of any staff involved in the audit of Huggins and the provision of other services for Huggins should
be different. (Similarly for Gray.)
Familiarity
Tutorial note: This arises when, by virtue of a close relationship with an audit client (or its management or employees) an
audit firm (or a member of the audit team) becomes too sympathetic to the client’s interests.
■ Long association of a senior member of an audit team with an audit client may create a familiarity threat. This threat
is likely to be greatest for Huggins, a long-standing client. It may also be significant for Gray as Fox & Steeple have had
dealings with this client for seven years now.
■ As Blythe is a new audit client this particular threat does not appear to be relevant.
■ Senior personnel should be rotated off the Huggins and Gray audit teams. If this is not possible (for either client), an
additional professional accountant who was not a member of the audit team should be required to independently review
the work done by the senior personnel.
■ The familiarity threat of using the same lead engagement partner on an audit over a prolonged period is particularly
relevant to Huggins, which is now a listed entity. IFAC’s ‘Code of Ethics for Professional Accountants’ requires that the
lead engagement partner should be rotated after a pre-defined period, normally no more than seven years. Although it
might be time for the lead engagement partner of Huggins to be changed, the current lead engagement partner may
continue to serve for the 2006 audit.
Tutorial note: Two additional years are permitted when an existing client becomes listed, since it may not be in the
client’s best interests to have an immediate rotation of engagement partner.
Intimidation
Tutorial note: This arises when a member of the audit team may be deterred from acting objectively and exercising
professional skepticism by threat (actual or perceived), from the audit client.
■ This threat is most likely to come from Blythe as auditors are threatened with a tendering process to keep fees down.
■ Peter may have already applied pressure to reduce inappropriately the extent of audit work performed in order to reduce
fees, by stipulating that there should not be an interim audit.
■ The audit senior allocated to Blythe will need to be experienced in standing up to client management personnel such as
Peter.
Tutorial note: ‘Correct’ classification under ‘ethical’, ‘other professional’, ‘practical’ or ‘staff implications’ is not as important
as identifying the matters.
(ii) Other professional and practical matters
Tutorial note: ‘Other professional’ includes quality control.
■ The experience of staff allocated to each assignment should be commensurate with the assessment of associated risk.
For example, there may be a risk that insufficient audit evidence is obtained within the budget for the audit of Blythe.
Huggins, as a listed client, carries a high reputational risk.
■ Sufficient appropriate staff should be allocated to each audit to ensure adequate quality control (in particular in the
direction, supervision, review of each assignment). It may be appropriate for a second partner to be assigned to carry
out a ‘hot review’ (before the auditor’s report is signed) of:
– Blythe, because it is the first audit of a new client; and
– Huggins, as it is listed.
■ Existing clients (Huggins and Gray) may already have some expectation regarding who should be assigned to their
audits. There is no reason why there should not be some continuity of staff providing appropriate safeguards are put in
place (e.g. to overcome any familiarity threat).
■ Senior staff assigned to Blythe should be alerted to the need to exercise a high degree of professional skepticism (in the
light of Peter’s attitude towards the audit).
■ New staff assigned to Huggins and Gray would perhaps be less likely to assume unquestioned honesty than staff
previously involved with these audits.
Logistics (practical)
■ All three assignments have the same financial year end, therefore there will be an element of ‘competition’ for the staff
to be assigned to the year-end visits and final audit assignments. As a listed company, Huggins is likely to have the
tightest reporting deadline and so have a ‘priority’ for staff.
■ Blythe is a local and private company. Staff involved in the year-end visit (e.g. to attend the physical inventory count)
should also be involved in the final audit. As this is a new client, staff assigned to this audit should get involved at every
stage to increase their knowledge and understanding of the business.
■ Huggins is a national operation and may require numerous staff to attend year-end procedures. It would not be expected
that all staff assigned to year-end visits should all be involved in the final audit.
Time/fee/staff budgets
■ Time budgets will need to be prepared for each assignment to determine manpower requirements (and to schedule audit
work).
(iii) Implications for allocating staff
■ Fox & Steeple should allocate staff so that those providing other services to Huggins and Gray (that may create a selfreview
threat) do not participate in the audit engagement.
Competence and due care (Qualifications/Specialisation)
■ All audit assignments will require competent staff.
■ Huggins will require staff with an in-depth knowledge of their computerised system.
■ Gray will require senior audit staff to be experienced in financial reporting matters specific to communications and
software solutions (e.g. in revenue recognition issues and accounting for internally-generated intangible assets).
■ Specialists providing tax services and undertaking the due diligence reviews for Gray may not be required to have any
involvement in the audit assignment.

正确答案：
5 BOLEYN & CO
(a) Professional Accountants
■ Professional Accountants are members of an IFAC member body. They may be:
– in public practice or employed professionals;
– a sole practitioner, partnership or corporate body.
■ Professional Accountants in Public Practice (‘practitioners’) are:
– each partner (or person occupying a position similar to that of a partner); and
– each employee in a practice providing professional services to a client irrespective of their functional classification
(e.g. audit, tax or consulting); and
– professional accountants in a practice having managerial responsibilities.
This term is also used to refer to a firm of professional accountants in public practice.
■ Employed Professional Accountants are professional accountants employed in industry, commerce, the public sector or
education.

正确答案：
4 NATE & CO
(a) – Money laundering is the process by which criminals attempt to conceal the true origin and ownership of the proceeds
of criminal activity, allowing them to maintain control over the proceeds, and ultimately providing a legitimate cover for
their sources of income. The objective of money laundering is to break the connection between the money, and the crime
that it resulted from.
– It is widely defined, to include possession of, or concealment of, the proceeds of any crime.
– Examples include proceeds of fraud, tax evasion and benefits of bribery and corruption.
Client procedures should include the following:
– Client identification:
? Establish the identity of the entity and its business activity e.g. by obtaining a certificate of incorporation
? If the client is an individual, obtain official documentation including a name and address, e.g. by looking at
photographic identification such as passports and driving licences
? Consider whether the commercial activity makes business sense (i.e. it is not just a ‘front’ for illegal activities)
? Obtain evidence of the company’s registered address e.g. by obtaining headed letter paper
? Establish the current list of principal shareholders and directors.
– Client understanding:
? Pre-engagement communication may be considered, to explain to Marcellus Fisher and the other directors the
nature and reason for client acceptance procedures.
? Best practice recommends that the engagement letter should also include a paragraph outlining the auditor’s
responsibilities in relation to money laundering.

正确答案：
(b) (i) Matters to consider
Materiality
The receivable represents only 0·2% (25,000/12 million x 100) of total assets so is immaterial in monetary terms.
However, the details of the transaction could make it material by nature.
The amount is outstanding from a company under the control of Pulp Co’s chairman. Readers of the financial statements
would be interested to know the details of this transaction, which currently is not disclosed. Elements of the transaction
could be subject to bias, specifically the repayment terms, which appear to be beyond normal commercial credit terms.
Paul Sheffield may have used his influence over the two companies to ‘engineer’ the transaction. Disclosure is necessary
due to the nature of the transaction, the monetary value is irrelevant.
A further matter to consider is whether this is a one-off transaction, or indicative of further transactions between the two
companies.
Relevant accounting standard
The definitions in IAS 24 must be carefully considered to establish whether this actually constitutes a related party
transaction. The standard specifically states that two entities are not necessarily related parties just because they have
a director or other member of key management in common. The audit senior states that Jarvis Co is controlled by Peter
Sheffield, who is also the chairman of Pulp Co. It seems that Peter Sheffield is in a position of control/significant influence
over the two companies (though this would have to be clarified through further audit procedures), and thus the two
companies are likely to be perceived as related.
IAS 24 requires full disclosure of the following in respect of related party transactions:
– the nature of the related party relationship,
– the amount of the transaction,
– the amount of any balances outstanding including terms and conditions, details of security offered, and the nature
of consideration to be provided in settlement,
– any allowances for receivables and associated expense.
There is currently a breach of IAS 24 as no disclosure has been made in the notes to the financial statements. If not
amended, the audit opinion on the financial statements should be qualified with an ‘except for’ disagreement. In
addition, if practicable, the auditor’s report should include the information that would have been included in the financial
statements had the requirements of IAS 24 been adhered to.
Valuation and classification of the receivable
A receivable should only be recognised if it will give rise to future economic benefit, i.e. a future cash inflow. It appears
that the receivable is long outstanding – if the amount is unlikely to be recovered then it should be written off as a bad
debt and the associated expense recognised. It is possible that assets and profits are overstated.
Although a representation has been received indicating that the amount will be paid to Pulp Co, the auditor should be
sceptical of this claim given that the same representation was given last year, and the amount was not subsequently
recovered. The $25,000 could be recoverable in the long term, in which case the receivable should be reclassified as
a non-current asset. The amount advanced to Jarvis Co could effectively be an investment rather than a short term
receivable. Correct classification on the statement of financial position (balance sheet) is crucial for the financial
statements to properly show the liquidity position of the company at the year end.
Tutorial note: Digressions into management imposing a limitation in scope by withholding evidence are irrelevant in this
case, as the scenario states that the only evidence that the auditors have asked for is a management representation.
There is no indication in the scenario that the auditors have asked for, and been refused any evidence.