01Our supervision
CMNC Associates Limited is registered with HM Revenue & Customs for Anti-Money Laundering Supervision as a business providing accountancy and related services. We are subject to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended.
Our CFO, Christina Christoforou, is a member of the Association of Chartered Certified Accountants and we work to the ACCA Code of Ethics and Conduct.
We work inside our clients' bank data. Anyone letting us do that is entitled to know what we are regulated for, what we will ask of them, and what we are obliged to do. This page says so plainly rather than burying it in an engagement letter.
02Customer due diligence
Before we begin any engagement, and periodically afterwards, we are required to identify and verify who we are dealing with. In practice we will ask for:
- Photographic identification and proof of address for directors and beneficial owners
- Confirmation of ownership and control, including anyone holding more than 25% of the business
- An understanding of the business, its activities and the source of its funds
We use electronic verification alongside documents. We cannot start work until this is complete, and we may need to repeat it if your ownership or circumstances change. This is not a comment on any client. It applies to everyone, without exception.
03What we are obliged to do
Where we know or suspect, or have reasonable grounds to suspect, that a person is engaged in money laundering or terrorist financing, we are required by law to submit a Suspicious Activity Report to the National Crime Agency.
We are prohibited by law from telling you that such a report has been made or is being considered. That prohibition is known as tipping off, and it overrides our normal duty of confidentiality to you. It is a serious criminal offence for us to breach it.
We may also be required to cease work on an engagement without being able to explain why. We recognise how that feels from a client's side, and we mention it here so it is never a surprise.
04Records and confidentiality
We retain customer due diligence records and supporting evidence for five years from the end of the client relationship, as the Regulations require, after which they are securely destroyed unless another legal obligation applies.
Outside our AML obligations and any other legal requirement, everything you share with us is confidential. How we handle personal data is set out in our Privacy Notice.
05Independence and conflicts
We do not broker transactions, we do not take referral fees or commission from lenders, brokers or advisers, and we have no financial interest in any deal our clients pursue. Our value depends on being unaffiliated, and we protect that deliberately.
If we become aware of a conflict of interest we will tell you, unless our confidentiality obligations prevent it. Where a conflict can be managed with appropriate safeguards, we will put those in place, guided by the ACCA Code of Ethics and Conduct. Where it cannot be managed, we will decline or withdraw from the work.
06The limits of what we do
Our reporting supports cash management decisions. It is not an audit and it is not an assurance engagement.
- Bank balances are reconciled to your accounting system and last filed accounts.
- All other data is taken as presented by you and your connected finance systems.
- We do not independently verify the completeness of your financial records.
We recommend our outputs are reviewed alongside your appointed accountant. Decisions taken on the basis of CMNC reporting are made at the client's own discretion.
07Raising a concern
If you have a concern about our conduct, contact us directly and we will investigate. If you remain dissatisfied, ACCA operates a complaints process for matters involving its members.