For Statutory Board Bonds to be included under the CPF Investment Scheme (CPFIS), they must satisfy a specific set of criteria outlined by the CPF Board. These bonds are required to be listed on the Singapore Exchange (SGX) and must be traded in Singapore dollars. A crucial condition is that their offering cannot be restricted only to institutional investors or accredited investors under Sections 274 or 275 of the Securities and Futures Act (SFA), ensuring they are accessible to retail investors. Furthermore, the bonds must not be subject to any trading restrictions in the secondary market. Finally, a prospectus that complies with SFA requirements must be issued for the bonds. In cases where the bonds are exempt from the prospectus requirement, an information memorandum detailing the terms of the issue, investment risks, and other relevant information must be issued and made available to CPF members. Other options incorrectly mix these criteria with those applicable to other instruments, such as the capital requirements for banks offering fixed deposits or the evaluation process for unit trusts.

Under the Securities and Futures Act (SFA), the status of an appointed representative is considered to have ceased if the representative stops acting for their principal for a continuous period of one month, and the principal has not notified the Monetary Authority of Singapore (MAS) of this cessation. This is an automatic cessation provision designed to ensure the Public Register of Representatives remains accurate and up-to-date, even if there is an administrative lapse by the principal. The other options are incorrect. The status does not remain active indefinitely pending the principal’s notification; the one-month inactivity rule supersedes this. The three-month validity period is characteristic of provisional or temporary representatives, not appointed representatives. Finally, while MAS has the power to revoke a registration, this specific scenario triggers an automatic cessation without requiring direct intervention from MAS.

This scenario illustrates a classic money laundering pattern involving the three key stages: placement, layering, and integration. The sudden influx of large funds from various unrelated international sources into an account with a previously stable and predictable transaction history is a major red flag for the ‘placement’ stage. This activity is inconsistent with the client’s declared business profile (a local boutique). The immediate use of these funds to purchase liquid securities is a ‘layering’ technique, designed to obscure the illicit origin of the money by converting it into another asset class and creating a complex transaction trail. Finally, the prompt transfer of these securities to an overseas institution represents the ‘integration’ stage, where the laundered funds are moved into the legitimate economy, making them appear clean. While the other options describe activities that can be suspicious in isolation, the correct answer accurately identifies the entire sequence of events as the most compelling evidence of potential money laundering, as outlined in the examples of suspicious transactions in MAS Notice SFA 04-N02.

When a transaction is executed in an overseas market, it falls under the legal and regulatory jurisdiction of that foreign country. The Monetary Authority of Singapore (MAS) regulates financial institutions operating within Singapore, but its authority and enforcement powers do not extend to compelling foreign regulatory bodies or market operators to enforce rules or intervene in disputes. An investor’s ability to seek redress for issues such as misconduct by a foreign entity is therefore governed by the laws and investor protection frameworks of that foreign jurisdiction, which can be substantially different from those in Singapore. While risks like the insolvency of a correspondent broker, differing disclosure standards, and restrictions on fund repatriation are all valid concerns mentioned in the Risk Warning Statement, they do not directly address the client’s specific misconception about the cross-jurisdictional enforcement power of MAS. The core issue raised by the client is about regulatory reach, a critical legal difference that investors must understand before trading in overseas markets.

Under the Securities and Futures (Licensing and Conduct of Business) Regulations, specifically Regulation 23, a Capital Markets Services (CMS) licence holder is permitted to advance its own money into a customer’s trust account for specific reasons, including to prevent the account from becoming under-margined or under-funded, or to ensure the continued maintenance of that account. The same regulation explicitly states that the CMS licence holder may retain any interest earned and returns arising from the moneys which it has advanced to the account. This is a specific exception to the general rule in Regulation 22, which states that interest earned from the customer’s money in a trust account shall accrue to the customer. Therefore, the firm acted appropriately by advancing the funds and is entitled to keep the interest generated by its own capital. The other options are incorrect because they either misstate the general rule by applying it incorrectly to the licensee’s funds, invent a requirement for client permission for this specific preventative action, or wrongly characterize a permitted action as a violation.

This question assesses the understanding of how a change in business activities for a Capital Markets Services (CMS) licence holder impacts its Base Capital Requirement (BCR) under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations. A ‘restricted broker’ is defined as a corporation that deals in securities only with accredited investors and does not accept client money or assets for settlement. Its BCR is S$250,000. When the firm expands its services to include retail clients and begins handling client funds, it no longer meets the definition of a restricted broker. The most appropriate new classification for a firm that is not a member of a securities exchange but deals in securities and holds client funds is a ‘non-member’ broker. According to the regulations, a ‘non-member’ broker is required to maintain a minimum base capital of S$1,000,000. Therefore, the primary impact is the reclassification and the corresponding significant increase in the required base capital. Becoming a ‘clearing member’ (S$5 million BCR) is a separate, higher-level function and not a direct consequence of this specific business expansion. An ‘introducing broker’ (S$500,000 BCR) typically does not carry customer positions in its own books, which may not align with the firm’s new model. Enhanced controls are necessary but do not substitute for the statutory capital requirements stipulated by the Monetary Authority of Singapore (MAS).

According to MAS Notice SFA04-N02 on Prevention of Money Laundering and Countering the Financing of Terrorism, a financial institution is not required to inquire into the ultimate beneficial owners (UBOs) of a customer under specific circumstances. One such exemption applies to an investment vehicle whose manager is a financial institution incorporated or established outside Singapore, provided that this manager is subject to and supervised for compliance with AML/CFT requirements that are consistent with the standards set by the Financial Action Task Force (FATF). The rationale is that such managers are already operating under a robust regulatory framework, mitigating the need for the Singaporean FI to conduct redundant UBO identification. The other scenarios, while potentially indicating a lower risk profile, do not constitute a formal exemption from the UBO identification requirement. A client’s long-standing relationship, a simple legal structure, or a low-risk investment strategy are factors to be considered in the overall risk assessment but do not eliminate the fundamental obligation to identify the UBOs.

The scenario describes a classic example of the ‘layering’ stage of money laundering. The client’s actions are designed to obscure the origin of funds by creating a complex series of transactions. The use of shell companies in a secrecy jurisdiction makes it difficult to identify the ultimate beneficial owner. The high-velocity trading of liquid securities is not for investment purposes but to create numerous, confusing financial layers. Transferring proceeds to various unrelated third parties in different countries further breaks the audit trail. This entire process is aimed at separating the illicit funds from their criminal source, which is the core definition of layering. The initial ‘placement’ stage would have involved introducing the cash into the system, and the final ‘integration’ stage would involve using the now-clean funds to acquire legitimate assets. The client’s indifference to investment performance is a key red flag that the transactions’ purpose is obfuscation, not profit, which aligns with the objectives of layering as outlined in the anti-money laundering framework, such as MAS Notice SFA04-N02.

A financial institution is required to perform Enhanced Due Diligence (EDD) when it assesses a customer relationship to present a higher risk for money laundering or terrorist financing. According to MAS Notice SFA04-N02, certain client types and transaction patterns are considered high-risk. In this scenario, the client entity is a personal asset holding vehicle, and it is receiving a significant, unexplained payment from an unassociated third party. Both of these are explicitly identified as high-risk indicators that necessitate EDD. The fact that the parent company is listed on a stock exchange, which could otherwise be a factor for considering Simplified Customer Due Diligence (SCDD), is overridden by these more immediate and significant risk factors. Therefore, applying SCDD or standard CDD would be inadequate. Relying on a third party’s due diligence is also not appropriate when clear high-risk flags are present at the onboarding stage, as the Singapore-based institution remains ultimately responsible for its risk assessment and compliance.

Under the MAS Notice SFA 04-N02 on Prevention of Money Laundering and Countering the Financing of Terrorism, financial institutions must be vigilant for transactions that could be related to tax crimes. The scenario presents several key indicators listed in Appendix E. The transfer of significant funds from a jurisdiction known for high tax evasion risk, coupled with the immediate purchase of a large quantity of precious metals not aligned with the client’s known business or background, is a major red flag. Additionally, the extensive use of safe deposit facilities without a clear and justifiable reason, along with vague explanations for the transactions, strengthens the suspicion. This combination of factors points strongly towards an attempt to obscure the origin of funds and evade tax obligations, rather than other illicit activities like terrorism financing or simple currency control violations, which often present different transactional patterns.

Under the Securities and Futures (Licensing and Conduct of Business) Regulations, a Capital Markets Services (CMS) Licensee is required to deposit all money received on account of its customers into a designated trust account. The regulations are specific about where these accounts can be maintained to ensure the safety and segregation of client funds. The permissible institutions are a bank licensed under the Banking Act or a merchant bank that has been approved as a financial institution under the Monetary Authority of Singapore Act. The rules do not extend to other types of financial institutions, such as finance companies licensed under the Finance Companies Act or insurance companies, for the purpose of holding these client trust accounts. This strict requirement is in place to uphold high standards of client asset protection within the capital markets industry.

The scenario describes a financial institution with specific operational constraints that align with the definition of a Wholesale Bank under the Singaporean banking framework. A key characteristic of a Wholesale Bank is its restriction on deposit-taking activities; it is permitted to accept Singapore dollar deposits only if they are S$250,000 or more and is not allowed to operate Singapore dollar savings accounts for the retail public. This allows them to service high-net-worth individuals and corporate clients without engaging in mass-market retail banking. In contrast, a Qualifying Full Bank has no such restrictions on its Singapore dollar deposit-taking activities. An Offshore Bank faces even stricter limitations, being generally prohibited from accepting Singapore dollar deposits from residents. A Merchant Bank, approved under the MAS Act rather than licensed under the Banking Act, cannot accept deposits from the public at all, making it an incorrect choice.

Under the Securities and Futures Act (SFA), the status of an appointed representative is considered to have ceased under several conditions to ensure the Public Register of Representatives remains accurate and protects the public. One such condition is when the representative has stopped acting for their principal for a continuous period of one month, and the principal has failed to notify the Monetary Authority of Singapore (MAS) about this cessation. This rule creates an automatic trigger for cessation, preventing a situation where an inactive representative remains on the register indefinitely due to an administrative lapse by the principal. The status does not solely depend on the principal’s formal notification, nor does it align with the three-month validity period for provisional or temporary representatives. The responsibility for notification lies with the principal, not directly with the representative to MAS.

According to the regulations outlined in the Securities and Futures Act (SFA), the status of an appointed representative ceases under several specific circumstances. One such circumstance is when the representative has stopped acting for their principal for a continuous period of one month, and the principal has not formally notified the Monetary Authority of Singapore (MAS) of this cessation. In this scenario, the 40-day period of inactivity exceeds the one-month threshold. Therefore, the representative’s status is considered to have ceased automatically by operation of law, even without an explicit notification from the principal or a direct revocation action by MAS. The responsibility lies with the principal to maintain up-to-date records and notify MAS promptly, but the failure to do so does not prevent the cessation from taking effect after the stipulated period of inactivity. This rule ensures that the Public Register of Representatives accurately reflects individuals who are currently active in the industry.

According to MAS Notice SFA04-N02 and the principles of financial crime prevention, a financial institution must have policies for the prompt reporting of any suspicious transaction. All staff are required to refer any suspicions to a designated single reference point, typically the Money Laundering Reporting Officer (MLRO) or a compliance officer. This internal escalation must be done promptly to allow for a timely investigation and a decision on whether to file a Suspicious Transaction Report (STR). The senior representative’s advice to delay the report directly contradicts this fundamental requirement. The obligation is to report suspicion, not confirmed illicit activity. Waiting for more evidence can obstruct the investigation process and expose the firm and the individuals to regulatory risk for failure to report in a timely manner. Filing an STR with the authorities is the subsequent step after an internal review, not the immediate action for the representative. The conversation itself is not tipping-off, as tipping-off involves prejudicing an investigation by alerting someone, usually external to the compliance function. The failure to maintain a register of STRs is a separate administrative breach that occurs after a report is filed, not at the initial stage of suspicion.

A Wholesale Bank is the most suitable choice. Under the Banking Act, Wholesale Banks can provide a full range of banking services but are restricted in their retail Singapore dollar (SGD) deposit-taking activities. They are not permitted to offer SGD savings accounts but can accept SGD deposits of S$250,000 or more. This aligns perfectly with the institution’s strategy to serve High Net Worth Individuals (HNWIs) and corporate clients while avoiding the mass retail market. A Qualifying Full Bank would be unsuitable as it is geared towards the full spectrum of banking, including mass-market retail services which the institution wants to avoid. An Offshore Bank is also unsuitable due to its severe restrictions on SGD business, particularly its inability to accept SGD deposits from Singapore residents. A Merchant Bank, approved under the MAS Act, is primarily focused on corporate finance and underwriting and is not allowed to accept deposits from the public, making it inappropriate for the described client deposit-taking needs.

The most critical and effective control in this scenario is to independently verify the instruction’s authenticity directly with the client. A mandatory call-back to a pre-registered and trusted phone number serves as a crucial verification step before executing an unusual and high-risk transaction. This control measure is designed to prevent external fraud, where an imposter might gain access to a client’s details and attempt to issue fraudulent instructions. Relying solely on email confirmation is less secure as email accounts can be compromised. While filing a Suspicious Transaction Report (STR) is important if suspicion remains after investigation, the primary step is to prevent the potential fraud from occurring through verification. Freezing the account without attempting to verify the instruction could inconvenience a legitimate client. This practice is a fundamental operational risk control measure emphasized under the MAS framework for preventing financial crimes, ensuring that firms have robust processes to validate client instructions, especially those that deviate from normal patterns, as outlined in the principles of MAS Notice SFA 04-N02 on Prevention of Money Laundering and Countering the Financing of Terrorism.

Under MAS Notice SFA 04-N02, financial institutions are required to identify and report suspicious transactions. The scenario presented contains multiple red flags listed in Appendix E. The most compelling reason for suspicion is the combination of several unusual activities that, when viewed together, lack a clear economic rationale. These include: the sudden influx of a large sum from an unrelated third party, which is inconsistent with the client’s known business activities; the immediate instruction to purchase a single, non-diversified security with no apparent investment strategy; and the subsequent request to arrange a back-to-back loan using these newly acquired assets as collateral without a plausible commercial purpose. This layering of transactions (deposit, purchase, collateralization) is a classic money laundering typology designed to obscure the origin of funds and integrate them into the legitimate financial system. Focusing on any single element, such as the source of funds or the type of security alone, is less indicative of suspicion than observing the entire sequence of events which collectively does not make economic sense.

Under the CPF Investment Scheme (CPFIS), corporate bonds must meet several specific criteria to be eligible for investment using Ordinary Account (OA) funds. One crucial requirement, as stipulated by the CPF Board and related to the Securities and Futures Act (SFA), is that the bonds must not be offered exclusively to institutional investors or accredited investors under Section 274 or 275 of the SFA. This rule ensures that the investments are suitable and accessible for the general public investing through their CPF funds. Therefore, a bond offered solely to accredited investors is ineligible, regardless of its credit rating. In contrast, a bond with an ‘A2’ rating from Moody’s meets the minimum credit rating requirement. The provision of an information memorandum is also acceptable for issues exempt from a full prospectus. The absence of secondary market trading restrictions is a mandatory condition for eligibility. Lastly, a Fitch ‘A’ rating is acceptable, and while allowing observers at meetings is a criterion for shares, it does not impact the eligibility of a bond.

Under the Securities and Futures Act (SFA), the primary violation committed is insider trading. The information regarding the loss of a major, non-public contract is considered ‘inside information’ as it is not generally available and a reasonable person would expect it to have a material effect on the company’s share price (SFA Section 216). The senior executive is a ‘connected person’ as defined in SFA Section 218. When the analyst, Mr. Tan, came into possession of this information, he was prohibited from dealing in the securities or procuring another person to deal in them. By urging his clients to sell their shares, he is ‘procuring’ them to transact based on privileged information, which is an offence under SFA Section 219. The other options are incorrect because the information was not false (it was true but non-public), he was not creating a false appearance of trading volume, and he was not disseminating information about a separate illegal transaction but was rather using confidential corporate information to commit an illegal act himself.

According to the Securities and Futures (Licensing and Conduct of Business) Regulations (SFR(LCB)), specifically Regulation 31 on Customer Agreements, a Capital Markets Services (CMS) licence holder providing custodial services must notify the customer of specific terms and conditions. One of these mandatory disclosures is the extent of the holder’s liability in the event of a default by the custodian, especially when the customer’s assets are held with a custodian other than the CMS licence holder itself. The other options, while related to the overall obligations of a CMS licence holder, are not required components of the customer agreement. The acknowledgment from the custodian that assets are held on trust and that the account is a designated trust account are requirements under SFR(LCB) 28, which governs the notification to and acknowledgment from the custodian, not the agreement with the customer. The maintenance of records on the custodian’s suitability is an internal obligation for the CMS licence holder under SFR(LCB) 29, not a term to be included in the customer agreement.

The detailed explanation for this question revolves around the concept of ‘securities hawking’ as defined under Section 309 of the Securities and Futures Act (SFA). Securities hawking is the act of making an offer or invitation to subscribe for or purchase securities during an unsolicited meeting with a potential investor. The primary purpose of this prohibition is to protect retail investors from high-pressure sales tactics, often seen in ‘boiler room’ operations, where they might be coerced into making hasty investment decisions without proper consideration. In the scenario presented, the representative’s action fits this definition precisely. The meeting at the alumni event was unsolicited in the context of a financial sales pitch. The representative initiated the discussion about a specific investment product without any prior appointment or expressed consent from the acquaintance to receive such a proposal. This action constitutes a direct breach of the securities hawking prohibition. The other options are incorrect because the scenario provides no information to suggest other forms of misconduct. There is no mention of the representative using non-public, price-sensitive information (insider trading), nor is there any indication of activities designed to manipulate the market (creating a false market). While failing to assess the client’s investment profile is also a breach of conduct rules (related to suitability), the initial act of making an unsolicited offer is the most direct and primary violation described, which is specifically addressed by the securities hawking rules.

Under the Securities and Futures (Licensing and Conduct of Business) Regulations (SFR (LCB)), a Capital Markets Services (CMS) licence holder is generally required to send a contract note to its customer by the next market day after a transaction. However, the regulations provide a specific exception for situations where a detail required for the contract note only becomes available later. In such cases, the CMS licence holder must issue the complete contract note by the next business day after that specific detail becomes available. In this scenario, the transaction occurred on Monday, but a crucial detail—the foreign stamp duty—was only confirmed on Tuesday. Therefore, the clock for issuing the contract note starts from when the final piece of information is received. The next business day after Tuesday is Wednesday, making it the final deadline for compliance.

According to the widely adopted ‘Three Lines of Defence’ model for risk management, which is a core concept in MAS Notice 626 on Prevention of Money Laundering and Countering the Financing of Terrorism, each line has a distinct role. The first line consists of the business units (e.g., front office, relationship managers) who own and manage risk directly. The second line, which includes the compliance and risk management functions, sets policies and oversees the first line’s adherence to them. The third line of defence is the internal audit function. Its primary role is to provide independent and objective assurance to the board and senior management on the effectiveness of the entire risk management and internal control framework, which includes evaluating the performance of both the first and second lines of defence. Therefore, when an independent evaluation of the entire AML/CFT control environment is required, it is the principal responsibility of the internal audit function. The compliance function (second line) cannot independently audit its own effectiveness, and the business units (first line) are the subject of the review, not the reviewers.

According to the principles of a risk-based approach (RBA) outlined in MAS Notice SFA04-N02, financial institutions must conduct a holistic assessment of all relevant Money Laundering and Terrorist Financing (ML/TF) risk factors. In this scenario, multiple high-risk elements are present. First, a Personal Investment Company (PIC) is considered a higher-risk business structure because it can be used to obscure the ultimate beneficial ownership and control of assets. Second, the ultimate beneficial owner’s (UBO) residency and citizenship in a jurisdiction known for high ML/TF risk is a significant red flag. While the company’s incorporation in a low-risk jurisdiction like New Zealand is a mitigating factor, it does not override the substantial risks posed by the business type and the UBO’s profile. A robust and dynamic risk evaluation system, as expected by regulators, would weigh the higher-risk factors more heavily, leading to an elevated overall risk rating for the client. This necessitates the application of Enhanced Customer Due Diligence (ECDD) measures. Relying solely on the country of incorporation would be a critical failure in risk assessment, as it ignores the substance of the client relationship. Similarly, mechanically averaging risks or ignoring the geographic risk of the UBO is not a sound practice and would be considered a deficient AML/CFT control.

Financial institutions have a critical responsibility to prevent the facilitation of financial crimes, including sanctions evasion. When dealing with complex ownership structures like bearer share companies, the primary challenge is the inability to identify the ultimate beneficial owner (UBO) with certainty. Bearer shares do not have a registered owner; ownership is determined by physical possession of the share certificate. This anonymity can be exploited by sanctioned individuals or entities (like Specially Designated Nationals or SDNs) to access the international financial system. If a Singaporean financial institution processes transactions for such an entity, even unwittingly, it would be in direct violation of MAS regulations, such as the notices prohibiting transactions with specific countries or individuals. Such breaches can lead to severe regulatory penalties, reputational damage, and legal consequences. While other risks exist, they are less central to this specific scenario. The risk of internal fraud is a general operational concern not uniquely tied to the client’s structure. Similarly, while external fraud through theft of certificates is possible, the institutional-level compliance risk of a sanctions breach is far more severe. Although the client could be involved in tax evasion, a predicate offense under the CDSA, the immediate and pronounced risk stemming from an unidentifiable UBO is the potential violation of specific, targeted sanctions and embargoes. Therefore, the most significant risk is the inadvertent facilitation of prohibited transactions.

According to the MAS Notice on Prevention of Money Laundering and Countering the Financing of Terrorism, a financial institution is generally not required to inquire about the ultimate beneficial owners (UBOs) of an investment vehicle if its manager is a financial institution supervised by the Monetary Authority of Singapore (MAS). A capital markets services licensee is supervised by MAS for compliance with AML/CFT requirements. The other scenarios do not meet the conditions for exemption. The exemption for MAS-supervised entities specifically excludes holders of a money-changer’s licence. For foreign financial institutions, they must be subject to and supervised for compliance with AML/CFT requirements consistent with FATF standards; a country on the FATF’s ‘grey list’ is identified as having strategic deficiencies, thus not meeting this criterion. Similarly, the exemption for listed entities requires the stock exchange to enforce adequate transparency regarding beneficial ownership, which is not the case if the exchange’s rules are known to be lax.

Under the Securities and Futures Act (SFA), the legal test for establishing insider trading liability differs between a ‘connected person’ and a ‘non-connected person’ (a ‘tippee’). For a tippee, who does not have a direct professional or business relationship with the corporation, the prosecution must prove that the individual had *actual knowledge* that the information they possessed was both price-sensitive and not generally available to the public. This is a higher burden of proof compared to that for a connected person (like an employee or director), where it is sufficient to show that they *ought reasonably to have known* the nature of the information. The law does not require proof that the tippee knew the insider was precluded from dealing, nor does it require an arrangement to share profits for the offence to be established. The core of the offence for a tippee lies in their state of knowledge about the information itself when they trade.

The detailed explanation for this question revolves around the extraterritorial application of Singapore’s market conduct rules as stipulated in the Securities and Futures Act (SFA), particularly under Section 196. The SFA is designed to protect the integrity of Singapore’s capital markets. To achieve this, its rules apply not only to actions committed within Singapore but also to actions committed outside Singapore if they affect securities listed or quoted on a securities market in Singapore, such as the SGX-ST. In this scenario, the representative’s manipulative trading, although executed from a location in another country, directly involved securities listed on the SGX-ST. Therefore, the act falls squarely within the jurisdiction of the Monetary Authority of Singapore (MAS) and is subject to the SFA’s market conduct provisions. The physical location of the person committing the act is irrelevant when the integrity of Singapore’s market is impacted. The other options are incorrect because the SFA’s jurisdiction is not contingent on the laws of the foreign country, nor is it limited by the type of trading account (personal vs. corporate) used for the misconduct.

Under the Securities and Futures Act (SFA), there is a critical distinction between a ‘connected person’ and a ‘tippee’ concerning insider trading. A connected person, like Ben the accountant, is someone who has access to price-sensitive information due to their professional or business relationship with the corporation. For a connected person, the prosecution only needs to establish that they ‘ought reasonably to have known’ that the information they possessed was not generally available and was price-sensitive. The burden of proof can shift to the connected person to prove otherwise. In contrast, a ‘tippee’, like Chloe, is a non-connected person. To secure a conviction against a tippee, the prosecution must prove that the tippee had ‘actual knowledge’ that the information was both price-sensitive and not generally available. It is not sufficient to argue they should have known; their actual state of mind must be proven. The other options are incorrect because a tippee does not need a professional relationship with the company, the intention to profit is not a necessary element of the offence, and the burden of proof is different for a tippee compared to the insider who provided the information.