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It was a big issue just after all the legislation first came in (maybe ten years, maybe more, I lose track) and no-one was quite sure what the rules were. One accountant certainly got done with the Institute arguing that he should have been aware given his professional knowledge (there was the suggestion that it was a convenient excuse but who knows).
aggi
Strikes me as bollocks but if you can find an example I’d be interested to see (as someone that has acted as an MLRO in the past).
No the one about the guy’s train tickets is not a relevant comparator.