David Holland, IPA Chief Inspector and Money Laundering Reporting Officer

IPA Insolvency Practitioner newsletter AML Digest, April 2025

Our last AML Digest focused on due diligence issues and was well received. For our first AML Digest of 2025, we are focusing on Suspicious Activity Reports (SARs).

Whilst due diligence is the main issue found on inspection visits where there are AML compliance failings, SARs failures are the main issue that results in a sanction and fine against members for AML compliance failures.

It is vital that members not only ensure that there is a clear policy and procedures regarding SARs, but that this policy is circulated and the requirements checked with staff to ensure that they understand their responsibilities and the policy is effective.

The frustration members have that there is no feedback from the National Crime Agency (NCA) as to SARs submitted is understood, but the number of SARs received by the NCA means that they cannot provide updates on SARs provided to them. The duty of members, and the IPA, is to report suspicions and we must all ensure that we do so.

Ensuring that your policy and procedures for SARs are robust is vital, as the NCA have advised that action may be taken against a ‘professional enabler’, which may include an IP, where a suspicion has not been reported, and it is considered that a report should have been made. The newsletter also provides a reminder of the OFSI reporting requirements that come into effect in May 2025 and details of the IPA’s AML & Fraud Conference in Birmingham on 25 September 2025.