David Holland, Chief Inspector and IPA Money Laundering Reporting Officer

IPA Insolvency Practitioner newsletter AML Digest, April 2023

Contents

• High-risk countries for money laundering purposes: Enhanced Due Diligence
• Proliferation Financing
• Ongoing monitoring of AML matters in an appointment
• SAR reporting
• Licences from OFSI
• Insolvency Practitioner identity fraud and scam websites
• Reporting misuse of bounce back loans
• NCA Amber Alert: High Net Worth Individuals and Tax Evasion (member login required to view)
• AASG alerts (member login required to view)
• Regulation 18 risk assessment reviews
• Reporting of material discrepancies of Companies House records
• Economic Crime Levy
• OPBAS Sourcebook
• How the 2017 Money Laundering Regulations have evolved
• ISS AML training
• OFSI webinar

AML continues to be an important part of the IPA’s regulatory work. This digest is published three times a year and collates information from recent IPA newsletters and training events as well as providing a reminder on regulatory matters with details on the IPA’s AML supervisory work and focus.

We hope that the content is useful. If you have any feedback on the contents or what you would like to see in future editions which would assist you in your AML work, please email us at aml@ipa.uk.com.

We have recently carried out a random ‘dip sampling’ review of Regulation 18 firm risk assessments received as part of licence renewals. Whilst there was a general improvement in the standard of the risk assessments, there are still some areas where there is a failure to consider the risks from money laundering on a firm basis. A breakdown of the main areas where better consideration of risks should be evidenced is provided in this issue.

The IPA is commencing further AML Compliance Reviews and AML Visits in the next few months. If you or your firm has had an Advisory Notice on updating or correcting an area of AML Regulatory Compliance, as part of our follow-up work to test the effectiveness of changes, an AML Compliance Review will be undertaken and you will be contacted by one of our Inspectors to carry out the review.

The IPA is also pleased to announce that we will be holding our first AML Roadshow in September this year. Look out for further details on how to attend the roadshow from our membership team when details are released later this year.

Finally, the IPA is subject to oversight regulation of our AML Regulatory work. OPBAS (Office For Professional Body AML Supervision) undertook a regulatory visit to the IPA at the end of 2022 and reported to the IPA on areas where we can improve our regulatory role. Expect to see updated guidance on matters such as Disclosures (previously known as whistleblowing) and further guidance on how breaches of AML Regulations will be considered and dealt with.