AML Frequently Asked Questions

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.

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. This link will be useful.

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.

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.

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.

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.

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 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

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:

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.

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.

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

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).

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.

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).

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’.

For Members in Practice based in UK (including Northern Ireland) please see the following below:

CCAB Guidance  

FATF Risk Based Approach for Trust and Company Service Providers

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017

The Money Laundering and Terrorist Financing (Amendment) Regulations 2019

Financial Sanctions Guidance

FATF Risk Based Approach for Accounting Profession  

For Members in Practice based in Republic of Ireland, please see the following below:

The Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2018

CCAB-I

For queries regarding your Members in Practice application or renewal, please email CIMA.MIPs@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.