Change in Distribution Method for AML Survey Forms (2022-08-19)

Summary

This is a CIMA general industry notice announcing an operational change in how it collects AML/CFT/CPF and Sanctions data from regulated financial service providers (FSPs). CIMA is retiring the separate AML Inherent Risk (AIR), AML Risk Controls (ARC) and Cash Flow Return (CFR) forms and combining them into a single new annual 'AML Survey', which will be issued and completed via a new platform called STRIX DCM (replacing/supplementing the Regulatory Enhanced Electronic Forms Submission portal for these purposes). The survey is issued under section 6(b)(ii) of the Monetary Authority Act to support CIMA's sectoral money laundering, terrorist financing, proliferation financing and sanctions risk assessments.

Rollout Schedule and Additional Surveys

• Sector rollout: The notice sets out a rollout schedule by sector, with each sector receiving the survey via email on a specified issue date and having to complete it by a specified due date.
• Insurance entities: Insurance entities will first receive an RFB Self Declaration to determine whether they conduct relevant financial business, and only qualifying entities will then receive the full AML Survey.
• Quarterly surveys: Separate quarterly surveys for VASP Travel Rule reporting and the Banking Cash Flow Return will be distributed through STRIX DCM at the end of each calendar quarter, due 30 days after issuance, starting with surveys issued on 30 September 2022.

Transition Instructions

• AIR/ARC forms: During the transition, FSPs are told not to use the AIR or ARC forms while they are being removed from the old portal.
• CFR form: No new CFR submissions are permitted; the CFR form remains available only for resubmissions or amendments to previously filed data.
• Contact details: FSPs are also asked to verify that the email contact(s) CIMA holds for them are correct, since the survey will be distributed to those addresses.

Key obligations

• FSPs must not use the AIR or ARC forms while CIMA removes them from the electronic forms portal.
• FSPs must not make new CFR submissions; the CFR form may only be used for resubmissions or amendments to previously filed data until further notice.
• FSPs in each listed sector must complete and submit the new combined AML Survey by the sector-specific due date once issued via STRIX DCM.
• Insurance entities must first complete the RFB Self Declaration survey; those indicating they conduct relevant financial business must then complete the AML Survey within 30 days of its issuance.
• Entities subject to VASP Travel Rule reporting and Banking Cash Flow Return must complete those quarterly surveys, distributed via STRIX DCM at the end of each calendar quarter, within 30 days of issuance.
• FSPs should verify with CIMA (via AMLsurveys@cima.ky) that the email contact(s) on file are correct, as the AML Survey will be sent to those addresses.

Applies to

Regulated financial service providers (FSPs), Securities: Full, Restricted and Registered Persons, Virtual Asset Service Providers, Insurance: Class A, Class B, Class C, Agents, and Brokers, Fiduciary: Trust, Company Manager, Corporate Service Providers, Banking: Class A, Class B, Building Societies, Credit Union, Development Bank and Money Services Businesses, Investments: Mutual Fund Administrators

Deadlines

• 7 October 2022: Due date for AML Survey for Securities (Full, Restricted and Registered Persons) sector, issued 12 September 2022.
• 7 October 2022: Due date for AML Survey for Virtual Asset Service Providers, issued 12 September 2022.
• 30 September 2022: Due date for Insurance RFB Self Declaration (Class A, Class B, Class C, Agents, and Brokers), issued 19 September 2022.
• 14 October 2022: Due date for AML Survey for Fiduciary sector (Trust, Company Manager, Corporate Service Providers), issued 19 September 2022.
• 21 October 2022: Due date for AML Survey for Banking sector (Class A, Class B, Building Societies, Credit Union, Development Bank and Money Services Businesses), issued 26 September 2022.
• 21 October 2022: Due date for AML Survey for Investments sector (Mutual Fund Administrators), issued 26 September 2022.
• 30 days after being deemed to conduct relevant financial business: Insurance entities confirmed via RFB Self Declaration to conduct relevant financial business will receive the AML Survey on 26 September 2022 and must complete it within 30 days.
• 30 September 2022 (first issuance), then quarterly: VASP Travel Rule reporting and Banking Cash Flow Return surveys will be issued via STRIX DCM at the end of each calendar quarter, due 30 days after issuance.