Tax advisers are obliged to establish and maintain ‘appropriate and risk-sensitive’ procedures which relate to:

(1)due diligence measures;

(2)reporting;

(3)record-keeping;

(4)internal control;

(5)risk assessment and management; and

(6)monitoring and management of such policies.

These policies and procedures include those which:

(1)identify and scrutinise:

(a)complex or unusually large transactions,

(b)unusual transactions which have no apparent economic or visibly lawful purpose, and

(c)any other activity which the adviser regards as likely to be related to money laundering or terrorist financing,

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