AML compliance: IPA supervisory focus for 2025
IPA Insolvency Practitioner newsletter AML Digest, December 2024
The IPA’s supervisory focus for 2025 will prioritise assessing the effectiveness of a firms’ policies and procedures in meeting the requirements of the Money Laundering Regulations (MLR).
This summary outlines the key areas of scrutiny during monitoring visits, highlighting the general expectations for IPs and their firms.
Building on the Regulation 18 and 18A risk assessments information IPs supplied as part of the renewal process, the IPA expects IPs to demonstrate that their AML controls are robust, effectively implemented, and understood across their organisations.
During supervisory visits during 2025, the IPA will review:
- Staff training and awareness: Firms must show evidence that all staff receive adequate AML training and have a clear understanding of their roles and responsibilities under the firm’s policies and procedures.
- Customer Due Diligence (CDD): IPs will need to demonstrate that their CDD measures are thorough and compliant with regulatory expectations.
- Suspicious Activity Reporting (SAR): The quality, timeliness and effectiveness of SAR submissions will be scrutinised to ensure firms are meeting their obligations.
The IPA reminds IPs of the importance of adhering to the Crown Prosecution Service (CPS) guidance on money laundering offences, which sets out the heightened diligence expected of regulated sector professionals. This includes exercising appropriate judgment when identifying and reporting suspicious activities, as outlined in the guidance here.
IPs should also consider the National Crime Agency (NCA’s) guidance on improving SAR quality, available here, and the broader NCA focus on Professional Enablers in the regulated sector.
As part of the 2025 supervisory cycle, the IPA will focus on IPs demonstrating effective:
- Staff training, policies and procedures
- Customer Due Diligence measures
- Quality SARs submitted in a timely manner
The IPA will expect firms to demonstrate that their AML policies and procedures are not only comprehensive but also effectively implemented and embedded into their day-to-day operations. By meeting these standards, IPs and their firms can play a vital role in combatting financial crime and maintaining the integrity of the profession.