Guidance and pro forma documents for use by small firms supervised by the CIOT

AMLGAS was updated in 2023 based on the legislation applying on 1 August 2022.  The CIOT have updated the pro forma to reflect this and other legislative changes since then.  They should be adapted to reflect the policies and procedures and risk assessment most appropriate for your firm.

Firms should consider reviewing their policies and procedures on a regular basis and we would recommend an annual review or more frequently where legislation or AML guidance has changed.

The current versions of the documents are available as follows:

• Practice wide AML risk assessment; and
• Practice AML policies and procedures

These are required by all firms under MLR 2017 regardless of size.  The documents will be most suitable for sole practitioner or small two partner/two director firms.

These documents are requested when the CIOT undertake AML supervision visits and may also be requested where random checks are undertaken to make sure that information provided by members on their registration forms is correct.  Failure to comply with requests for these documents or if we find that you have given incorrect information on the form will result in a referral to the Taxation Disciplinary Board.