2014/2015
CIMA ANNUAL RETURN
Please ensure you complete the current version of the AML/CTF annual return (2014/2015 version) and that
you have read the guidelines for completion (available in the Members’ Handbook).
The risk of money laundering or terrorist financing varies according to client demographic, the services offered
and the jurisdictions operated in. To better understand, and mitigate the associated risks, members must
undertake risk assessments of their practice. To meet obligations for AML/CTF purposes they must complete
CIMA’s annual return.
If you are yet to take on clients then theoretical answers should be given, i.e. what you would/will do when
clients are in place.
Use of your personal information: Answers to the questions below will be treated as confidential. CIMA will
use the information provided to understand its supervised sector and discharge its supervisory duties under
the Money Laundering Regulations 2007
YOUR PRACTICE
Name and CIMA contact ID
Country of residence and practice
Are you registered for AML/CTF supervision with another professional body? If so simply name the body and
sign and upload this annual return. You are not required to answer any further questions.
Yes
No
If your answer to the question above was yes, please name the professional body:
1. Please indicate which best describes the size of your client base (number of clients)
1 – 10
11 – 50
51 – 100
101 – 249
250 +
2. Total number of staff including yourself
1 (Sole practitioner)
2
3–5
3. Please indicate your business type
Sole practitioner
Partnership
6 – 10
11 – 20
21 – 50
51+
Limited Company
Limited Liability Partnership
Other, including non UK jurisdiction (please specify)
.
4. Does your practice operate from a single office location or from multiple business units?
Single
Multiple
If multiple how many locations and in what country/ies
5. How do you maintain awareness of AML/CTF threats to your practice?
6. What do you consider to be the main AML/CTF threats to your practice?
Why?
How do you mitigate them?
7. Do you complete a documented AML/CTF risk assessment on your practice as is legally required by
AML/CTF regulation? Yes
No
7a. Please describe your risk assessment process and documentation.
OTHERS HOLDING A MANAGEMENT INTEREST IN YOUR PRACTICE
If you are a sole practitioner you are not required to complete this section, please continue to 9.
8. Please list any other Directors / partners within your practice
Name
Position held
Name of professional body of which they are a member*
Who is their supervisor for AML/CTF compliance?
Name
Position held
Name of professional body of which they are a member
Who is their supervisor for AML/CTF compliance?
Name
Position held
Name of professional body of which they are a member
Who is their supervisor for AML/CTF compliance?
*if they do not hold membership of a professional body please leave blank
YOUR CLIENTS
Risk assessments and customer due diligence checks on all clients should be made at the point of
engagement and continued periodically.
9. How do you assess client risk?
10. What level of risk from money laundering / terrorist financing would you associate with your client base?
Low risk
higher risk
11. Please explain on what basis you have allocated the above risk level
12. Is the larger proportion of your client base composed of clients who are:
New
Longstanding
Friends/family
Recommended from person known to you
13. Do you have any particular client sector/client type that you consider higher risk?
If yes, which and why?
Yes
No
14. Do you offer any particular service/product that you consider to be higher risk?
If yes, which and why?
Yes
No
15. Businesses with a large cash income (e.g restaurant owners, shopkeepers, taxi drivers, car dealers etc)
can be seen as a higher risk.
Do you deal with cash based businesses?
Yes
No
If yes, what percentage of your client base are cash based businesses?
%
16. Do you have any Politically Exposed Persons (PEP’s) as clients?
Yes
No
17. Do you have any family or close associates of PEP’s as clients?
Yes
No
18. Do you work with agents or representatives of an individual as clients?
If yes, what checks are undertaken to establish the beneficial owner of the business?
Yes
No
19. Do you have clients that you (or your staff) have not met face to face?
If yes, please describe the enhanced due diligence checks you undertake
Yes
No
20. Do you have any clients where the ownership of the business is obscured?
If yes, please describe the enhanced due diligence checks you undertake
Yes
No
21. How many, if any, clients have you turned away due to them being unable to comply with CDD
requirements
Did you take any further action on those turned away, if so, please explain
22. The Financial Action Task Force (FATF) publish a list of high risk and non-cooperative jurisdictions with
regards to their AML/CTF regimes and require Enhanced Due Diligence (EDD) to be applied in response to
these.
Do you operate or have clients based in any of the published FATF jurisdictions?
Yes
No
If yes, please indicate where and in what capacity.
23. What Customer Due Diligence (CDD) documents or materials do you require new clients to provide
you with?
24. Please confirm that you keep secure records of you CDD in respect of each client and retain them
for at least 5 years.
Yes
No
25. How do you make clients aware of your obligations to meet AML/CTF regulatory requirements?
YOUR SERVICES
26. Do you offer any accounting or financial services other than those defined in CIMA’s Member in Practice
Rules (point 2)?
Yes
No
If yes please specify.
27. What services does your practice offer predominately? (maximum of three)
1.
2.
3.
28. What sectors does your practice serve predominately? (maximum of three)
1.
2.
3.
*e.g. commercial, manufacturing, retail
39. Do you offer the provision of registered office, business address, correspondence or administration
address? Yes
No
30. Do you act or arrange for a person to act as a partner of a partnership?
Yes
No
31. Do you arrange for another person to act as a Director or Secretary of a company?
Yes
No
32. Do you offer services forming companies or other bodies corporate?
Yes
No
33. Do you offer services for the buying and selling of business entities?
Yes
No
34. Do you offer off shore company registration?
Yes
No
35. Do you offer services for the buying and selling of real estate?
Yes
No
36. If you offer tax services, tick which of the following apply
Tax compliance
Tax planning
37. Do you hold a tax qualification*?
If yes, with which awarding body?
*Please note, CIMA is not a tax qualification
Yes
No
38. Do you hold client money, securities or other assets?
If yes please give details and to what amount
Yes
No
39. Do you manage bank, savings or security accounts?
Yes
No
TRAINING AND GUIDANCE
40. What training have you undertaken in AML/CTF matters as required by AML legislation? (Where relevant
please give dates and the name of the training provider)
41. What arrangements do you make for AML/CTF training for your staff?
42. CIMA provides a free online course for its UK members in practice on anti-money laundering / counter
terrorist financing (AML/CTF) covering:
• Money laundering regulations, obligations and penalties for non-compliance
• Assessing the risks to the business
• Customer due diligence (CDD)
• How to identify and report suspicious activity
• Record keeping
Have you completed CIMA’s AML/CTF course?
If no, please indicate why
Yes
43. Have you attended any of CIMA’s AML/CTF events?
If yes, please indicate which event and date attended.
Yes
No
No
INTERNAL AML/CTF PROCEDURES OF YOUR PRACTICE
Internal systems and controls should reflect the degree of associated risk to the business. It is the Money
Laundering Reporting Officer’s (MLRO’s) duty to maintain AML/CTF processes and procedures robustly and to
identify any weaknesses and mitigate them.
44. Are you the MLRO?
If not, please supply the name of your nominated officer.
Yes
No
45. How do you review the effectiveness of your procedures?
REPORTING SUSPICIOUS ACTIVITY
All businesses regulated under money laundering regulations must report any suspicious activity to the
Financial Intelligence Unit specific to their country (members in the UK are required to submit Suspicious
Activity Reports (SAR’s) to the National Crime Agency (NCA).)
46. Have you made any SAR’s or global equivalent during the past year?
47. If so, how many?
Signature
Date
(typed signatures are accepted)
Yes
No