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31 March 2020: Coronavirus Update. The situation is fast moving and we are continuing to monitor the global situation and its impact on our members, staff, exam candidates, students and the profession. More information for Members and Students in My CIMA.

AML Frequently Asked Questions

To help answer your queries, Professional Standards have put together a FAQ page in the CIMA Members in Practice handbook.

I am a CIMA student, can I register as a CIMA Member in Practice?

No. As a CIMA student you cannot register as Members in Practice because you are only part way through your CIMA Qualifications. CIMA students however, can register with HMRC.  

If you would to apply for HMRC AML supervision please see the following link https://www.gov.uk/guidance/register-or-renew-your-money-laundering-supervision-with-hmrc

I am a CIMA student, and complete self-assessment for family and friends can I be supervised by CIMA?

No. CIMA students cannot be supervised for AML/CTF with CIMA. If you are completing self-assessments on behalf of family and friends, then please get in contact directly with HMRC. The following link will be useful https://www.gov.uk/government/organisations/hm-revenue-customs/contact/self-assessment

Are agents of clients allowed access to client accounts to make payroll payments?

Yes. If there is a formal agreement in place, Members in Practice are allowed to have access to client accounts. Payroll is classed as a higher risk service for money laundering, so if you notice anything suspicious you will be obligated to report directly to the NCA.

I have another director within my practice who is offering accountancy services, can they be too be registered for AML supervision with CIMA?

No. CIMA can only supervises its own CIMA members. If there is another Beneficial Owner, Officer, Manager (BOOM) or director within the practice who is offering accountancy services, then they will need to be supervised with their own AML supervisory body. If they are not a member of another professional body, then they will need to apply for AML supervision with HMRC. For further information, please see HMRC website.

Please note, that under Reg 52, where an individual is supervised by another supervisory authority,  the supervisor is required to disclose this information to CIMA.

I am supervised for AML/CTF with another body, do I still need to be supervised with CIMA?

No. If you already supervised for AML/CTF with another body then you do not need to be supervised by CIMA. However, you would be required to disclose this information within your AML/CTF Annual Return.

How do I disclose that I am supervised by another body within my Annual Return application?

Once you have accessed the annual return via your MYCIMA account, you will be required to complete Q1 and Q2 in the AML/CTF Annual Return.

What are financial sanctions and how do I ensure I comply under the UK legislation?

Financial sanctions are restrictions put in place by UN, EU or UK. The Office of Financial Sanctions (OFSI) issue a consolidated list of persons who are subject to financial sanctions. A designated person refers to an individual, entity or body, listed under EU or UK legislation as being subject to financial sanctions.

Please see the following link on financial sanctions consolidation list  financial sanctions consolidated persons list as this is regularly updated. Please also have a read up on how to report financial sanctions. More information can be found in the CIMA’s members Handbook

I have been approached by a client, but it is not clear who is part of the organisation structure, where can I find this information?

As part of your client due diligence requirements you will need to identify who the beneficial owners within the business are. A Beneficial owner is defined as:

A sole practitioner;

A partner, or LLP member, in a firm who:

  • holds (directly and indirectly) more than 25% of the capital, or profits or voting rights; or
  • exercises ultimate control; and

A shareholder in a limited company who:

  • holds (directly and indirectly) more than 25% of the shares or voting rights; or
  • ultimately owns or exercises ultimate control. 

If your client has a large business, there may be several beneficial owners. You may use your current electronic verification software systems to identify who the individuals are. You can also check additional information such as company structure, Companies House and other information you have obtained directly from your client.

In addition to this, you are required to check if the clients are PEPs (domestic and overseas), as well as family members and known close associates.

Section 5.1.17 of The CCAB Guidance also has further guidance on complex structures of beneficial ownership.

I have a contract agreement with a third party and will receive payment directly via the third party, am I required to undertake CDD on the client?

Yes. In cases where Members in Practice have a third-party contractual agreement to undertake contractual work, the usual Client Due Diligence requirements will apply. It may be worth having a look at the MLR 2017 (Reg 27) and (Reg 28).

The CCAB Guidance ‘Section 5’ is very useful as it breaks down the CDD requirements in practical way.

You may also find it useful to look ‘Appendix E’ of the CCAB guidance that provides further information on high-risk factors and low risk factors.

I have been selected for a site visit, is there any guidance to help me prepare for the visit?

All information on the AM/CTF site visits can be found here. (CIMA login required).

I have client who raises some concern over suspicious activity, what should I do?

If you are Member in Practice based in the UK, we advise that if you have any concerns over suspicious activity to raise a Suspicious Activity Report (SAR) to the National Crime Agency (NCA). For further information on how to submit a SAR, please see here.

In all cases where a SAR has been raised you must ensure that you comply with your obligations to not tip off the client (Section 333 of the POCA)

If you are a Member in Practice based in Republic of Ireland you should raise a suspicious transaction report (STR) to the Compliance Officer (if applicable) or directly to the Garda Síochána and the Revenue Commissioners (for example, if the client has been deliberately difficult or evasive).

I am interested in obtaining electronic software to undertake client due diligence. Does CIMA endorse any software that Members are eligible to use?

No. CIMA does not currently endorse any electronic software. However, it is important for these electronic checks to cover all key areas, beneficial ownership, client due diligence including; PEPs (domestic and overseas), as well as family members and known close associates and risk assessment.

Does CIMA offer any AML training courses or resources that I can use within my practice?

CIMA does not currently offer any AML training courses for Members in Practice. CIMA does however, have the following available in the Members Handbook:

AML/CTF webinars

AML/CTF Compliance guidance  

We encourage our Members in Practice to use this guidance to ensure policies and procedures are implemented to improve robustness within your practice and mitigate any risks.

AML/CTF Templates (AML/CTF Policy, Practice Risk Assessment and CDD templates).

My clients are Churches/Charities, how do I find who the beneficial owners are?

If you have clients within this sector, the best source of information regarding your query is the Joint Money Laundering Steering Group (JMSLG). Please see Part I, Section 5.3 ‘Charities, Church Bodies and Places of Worship’ on this website https://www.jmlsg.org.uk/industry-guidance/article/jmlsg-guidance-current

I have a general question about my Members in Practice application who do I contact?

For queries regarding your Members in Practice application or renewal, please email pc.applications@aicpa-cima.com

If you have any further queries regarding the AML return or process, please email aml@aicpa-cima.com as this is a dedicated mailbox for AML/CTF queries.