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Minimising risk

Members must undertake steps to minimise the risk of money laundering to their business and to remain compliant with money laundering legislation.

The Money Laundering Regulations 2017  and The Money Laundering and Terrorist Financing Regulations (Amendment) Regulations 2019 set out your obligations under the UK’s AML/CTF regime. HM Treasury has determined that there should be one piece of AML/CTF guidance for each regulated sector that it will approve. The guidance for the accountancy sector can be found here. It has been updated to reflect the (Amendment) Regulations 2019. 

CIMA has produced these materials to assist members in the UK in complying with their AML/CTF obligations.

UK

AML/CTF Compliance Checklist

As a Member in Practice it is important to remain compliant under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. CIMA has put together a checklist as a guide to ensure policies and procedures are implemented to improve robustness with your practice and mitigate and risks to your practice. 

AML/CTF Compliance Checklist document

AML/CTF Policy

The AML/CTF regime in the UK requires you to have AML/CTF policies that cover specified areas. The sample policies below can be amended to suit your own practice:


AML/CTF Policy (UK)

Practice Risk Assessment

The AML/CTF regimes in the UK requires a risk assessment of your practice to be conducted and documented, to identify what money laundering and terrorist financing risks your practice may face and how you will control them. The templates below can be amended to suit your own practice:

Practice Risk Assessment Template (UK)

Practice Risk Assessment Template (UK Mac Version)

Your assessment must take into account information made available by your supervisory authority. CIMA has worked with the other accountancy bodies to produce the below assessment of circumstances where there might be a high risk of money laundering or terrorist financing:

Circumstances where there might be a high risk of ML or TF

CDD and Client Risk Assessment Processes

The AML/CTF regime in the UK requires you to perform CDD. This includes gathering information on the intended purpose and nature of the business relationship.

The CDD forms below can be used to formally record information you obtain.
You are also required to demonstrate that the level of CDD you have applied to a business relationship is appropriate to the level of risk. When assessing the level of risk you are required to take into account certain factors.
The CDD forms also contain a client risk assessment process to assist you in demonstrating how you have assessed the level of risk: 

CDD and Client Risk Assessment – Corporates (UK)
CDD and Client Risk Assessment – Individuals (UK)

Republic of Ireland

For members in Republic of Ireland, your obligations are set out in The Criminal Justice (Money Laundering and Terrorist Financing) (Amendment) Act 2021. CIMA has produced the below materials to assist members in Ireland in complying with their AML/CTF obligations.

AML/CTF Policy

The AML/CTF regime in Ireland requires you to have AML/CTF policies that cover specified areas. The sample policies below can be amended to suit your own practice:

AML/CTF Policy (Ireland)

Practice Risk Assessment

The AML/CTF regime in Ireland requires a risk assessment of your practice to be conducted and documented, in order to identify what money laundering and terrorist financing risks your practice may face and how you will control them. The template below can be amended to suit your own practice:

Practice Risk Assessment Template (Ireland)

CDD and Client Risk Assessment Processes

The AML/CTF regime in Ireland requires you to perform CDD. This includes obtaining information on the purpose and intended nature of a business relationship. The below CDD form can be used to formally record information you obtain.

You are also required to perform a risk assessment of the business relationship that takes into account certain factors and keep a record of this assessment. The below CDD forms contain a client risk assessment process to assist you in demonstrating how you have assessed the level of risk. The level of CDD you apply must be appropriate to the level of risk.

CDD and Client Risk Assessment - Individuals (Ireland)

CDD and Client Risk Assessment - Corporates (Ireland)

 Please also see the CCAB Guidance for Ireland for further guidance.

Failure to comply with the regulations

It is a criminal offence under the UK and Ireland regimes to fail to comply with your AML/CTF obligations. CIMA’s materials aim to assist you in complying. However, they are intended as a sample only, and your obligations go beyond the areas they cover. Members must still familiarise themselves with their obligations under their respective legislation and the guidance for their sector.