ACRA's and Law Society's (LawSoc) Anti-Money Laundering/ Countering the Financing of Terrorism (AML/CFT) review on Registered Filing Agents (RFAs) and law practices, require firms to have Internal Policies, Procedures and Controls (IPPC) implemented firm-wide and documented in an IPPC document.

If you are a RFA, prior to the review, you are to download a Self Assessment Form and complete the form.  There are heavy weightage place on the RFA's implementation of Section B - Risk based approach and risk assessment, Section C - IPPC document, and Section D - Customer Due Diligence (CDD) and beneficial ownership information.

For busy professionals like yourself, or you are not sure how to develop an IPPC document, you can now purchase a customizable IPPC document which includes:

IPPC document template

Risk assessment template

CDD forms, and

1 hour training to guide you how to develop IPPC.

These templates are delivered in Microsoft Word/ Excel format, and are almost 90% complete for your firm to use.  With these templates and training, you can adjust and customize to your firm's requirements, and be ready for ACRA or LawSoc AML/CFT review!

Contents of IPPC Template:

1. INTRODUCTION
2. POLICY STATEMENT
3. MANAGEMENT OVERSIGHT
4. RISK ASSESSMENT
5. CUSTOMER DUE DILIGENCE (“CDD”)
6. ENHANCED CUSTOMER DUE DILIGENCE
7. RECORD KEEPING
8. ON-GOING MONITORING
9. REPORTING A SUSPICIOUS TRANSACTION
10. AUDIT AND COMPLIANCE
11. HIRING OF NEW STAFF AND TRAINING
APPENDIX A AML/CFT ROLES & RESPONSIBILITIES
APPENDIX B RISK ASSESSMENT
APPENDIX C INDICATORS OF SUSPICIOUS TRANSACTIONS

Customer Due Diligence Forms:

Form 1 Customer Information
Form 2 Client's Particulars (Individual or Entity)
Form 3 Politically Exposed Person Information
Form 4 Risk Assessment