Continuity of Practice Agreement

Budlia10

Having just had my first review as a MIP. I am somewhat daunted by the work I need to do within the next 2 working weeks to comply to the Summary of findings. I have a very small practise and work in a business as an employee 2 days a week. Could anyone let me know how they got when they had their review. The difference in size of our practises must be huge and I think the smallest ones are being asked to comply to regulations on the same scale as the largest, which I'm sure employ staff and subcontract work etc.... eg The Continuity of Practice Agreement in the past Ive just had a verbal agreement. But according to the review summary I need to provide legal documents and hire a solicitor to make it a formal legal document. Surely this cant be the case.....please let me know ....Thankyou Kind regards R Langley

MarieNoelle

Hi
a template of a professional nominee contract can be found on the AAT website - through MyAAT- toolkit - conduct of work - templates.

I agree it seems maybe over the top for a sole practitioner with a few clients but I guess you have to think of the worst case scenario. I also worked on the basis of a less formal agreement and was asked after a review to formalised this. I don't think you necessarily need a solicitor, but this is something I need to check with the MIP team.

I took the practice review as an opportunity to ask lots of questions regarding how to comply with regulations that seem to have been written for larger businesses. You have to adapt the regulations so you still comply without going over the top. I find the AML toolkit sent by AAT is very useful for recording your review of the risks and procedures for AML.

I hope this helps.