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MPF intermediaries
MPFMPF Intermediaries ExaminationAn agent tells a customer that the insurer's MLRO is looking into the customer's unusual top-up, although nothing has yet been reported to the JFIU. This is:
Answer: tipping off, which can apply before any report reaches the JFIU. Tipping off covers revealing information that might prejudice an investigation, including where a suspicion has been raised internally but not yet reported to the JFIU.Why not the others:• a breach of PDPO Principle 3 only: The conduct is the tipping-off offence under the DTROP, OSCO and UNATMO.• acceptable, because no STR has been filed yet: The tipping-off provision covers suspicions raised internally that have not yet been reported.• required by the agent's duty under GP 5 to give the client accurate and adequate information: The duty to give clients accurate information does not extend to revealing an internal suspicion.Watch out: Thinking tipping off needs a report already filed with the JFIU.Rule: Tipping off: revealing information that might prejudice an investigation is an offence; it includes internal suspicions not yet reported to the JFIU.Source: IA Investment-linked Long Term Insurance Examination Study Notes, 2024 Edition (7th ed., Nov 2024; for exams from 17 Feb 2025), 5.4.1(b)(vii), p. 5/20
Thinking tipping off needs a report already filed with the JFIU.
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