David Holland, Chief Inspector and IPA Money Laundering Reporting Officer

IPA Insolvency Practitioner newsletter AML Digest, November 2022

Contents

• AML 2021/22 Annual Report and 2022/23 Sector Risk Assessment
• Awareness of CEO fraud and impersonation frauds
• Amendments to the 2017 Money Laundering Regulations
• SARs Reporter Booklet
• Ongoing monitoring and review of a business relationship – Reg 28(11) Money Laundering Regulations 2017
• Accountancy AML Supervisors’ Group alerts
• Sanctions
• SAR Reform Programme
• SAR Glossary Codes
• Renewals
• Supervisory work for 2022/23
• ISS AML training and IPA Learning

The IPA is continually assessing the AML risks it members face. Over the last 18 months, we have seen a dramatic rise in the frequency of risks being reported by our supervised population relating to abuse of Covid support measures and the Redundancy Payments Service.

The chances of an IP being involved in an appointment where potential criminal proceeds have been involved has greatly increased, and it is important that all members review the effectiveness of their policies, procedures and staff training. We expect our members and their staff to be able to demonstrate knowledge of current risks posed from money laundering, terrorist financing and sanctions breaches. A key function is our focus on a firm’s risk assessment, but this must be supported by evidence of staff training and the effective review of risks and how these can be minimised.