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MPF intermediaries
MPFMPF Intermediaries ExaminationDuring an investigation, a subsidiary intermediary gives the investigator a backdated client form, intending to defraud. On conviction on indictment, the maximum penalty is:
Answer: $1,000,000 and imprisonment for 7 years. Producing a false or misleading record with intent to defraud, in purported compliance with an investigation requirement, carries $1,000,000 and 7 years on indictment.Why not the others:• $100,000 and imprisonment for 6 months: that is the maximum on summary conviction, not on indictment.• $200,000 and imprisonment for 1 year: that is for failing to comply without reasonable excuse, with no fraud.• $1,000,000 and imprisonment for 2 years: that is for producing false material knowingly or recklessly, without intent to defraud.Watch out: Missing that intent to defraud moves the offence into the highest tier.Rule: Intent to defraud (items ii, iv, v): indictment $1m + 7 years; summary $100,000 + 6 months.Source: MPF Study Notes, Tenth Edition (June 2026; examinable from 1 Oct 2026), section 7.2.6(c) (checked 31 Oct 2026)
Missing that intent to defraud moves the offence into the highest tier.
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