IPA Insolvency Practitioner newsletter AML Digest, December 2025
The IPA is to provide our response to the HM Treasury consultation on the duties, powers and responsibilities of the FCA as AML Supervisor by 19 December 2025. The main points of our response will be:
- The IPA welcomes the opportunity to work closely with the FCA on the transfer of AML supervision from the IPA to the FCA for IPs and to assist the FCA in work on assessing sectoral risks and developing relevant training and guidance.
- The IPA’s overriding concern is the loss of insolvency sector specialism and expertise. The IPA has worked closely with OPBAS and other insolvency stakeholders regarding insolvency-specific guidance, and it is vital that specific risk issues and compliance matters are retained and the quality and standard of IP regulatory compliance is not reduced.
- There are concerns over the proposal for the FCA to designate if an IP is a fit and proper person which will be taking a power from the IPA under the Insolvency Act 1986 and add to the regulatory burden of IPs.
- The key to effective AML/CTF Supervision and the IPA’s supervision of our licensed IPs working together is in an early and clear information sharing agreement and process.
- Further information on the cost of the proposals, including the costs to individual IPs (and other relevant persons) with an impact on the current AML/CTF Supervisory Authorities is required to consider more fully any burden on different levels of firms.
We will publish our full response after it has been provided to HM Treasury. As a reminder to members, if you wish to respond to the consultation, responses can be sent by 24 December.