These are the:
- Terms of engagement.
- Continuity agreement.
- Internal complaint handling procedure.
- Professional Indemnity Insurance (PII) certificate.
All Members in Practice who are supervised by CIMA for AML/CTF compliance are also required to submit copies of the following documents:
- Practice Risk Assessment
- AML/CTF Policy
- CDD and Client Risk Assessment process
CIMA expects members to comply with the request for the above documents within 28 days, as set out in the Member in Practice Rules. If members require any additional guidance or support during that time please contact firstname.lastname@example.org as soon as possible.
It is mandatory that you have written copies of the above documents under current money laundering regulations. Further information on these documents can be found on the ‘Minimising Risk’ page of the Members’ Handbook.
The members in practice rules state that members in practice must comply with any scheme operated by the institute, which includes procedures for monitoring compliance with the provisions of these rules.
If you are unsure what is required for your practice, please review the Business structures and mandatory requirements document, this an idea of what type of documents are required for the different types of practices.
Quality assurance checks ensure that members have all mandatory requirements in place and that they meet CIMA's standards. Each year a random sample of members in practice are selected for quality assurance monitoring and are notified by email. As part of those checks CIMA will issues guidance on the content of the documents if there are any essential elements missing.
CIMA does not prescribe the content of mandatory requirement documents, however it is expected that you advise the client of your obligations to work within the CIMA code of ethics and anti-money laundering legislation in your terms of engagement. Continuity agreements must be signed and dated by both parties.
Members can check their own documents against CIMA's examples and guidance which can be found in the mandatory requirement section of the handbook.
At the same time staff will check that the PII details are up to date on your record and issue a reminder if necessary. Clear terms of engagement and accessible, understandable complaints handling procedures should help to prevent a problem arising or at least from escalating.