Examples and case studies

Useful tools that help IPs to be alert to risk indicators and ‘red flags’ (which might provide reason to suspect money laundering or terrorist financing) include the use of examples and case studies. The IPA will continue to highlight risk indicators and ‘red flags’ in this way, while anonymising case studies as appropriate.

Agile money laundering personas

The National Risk Assessment for 2020 highlights that ‘There continues to be a risk that criminals will exploit company liquidation and associated services … to mask the audit trail of money laundered through a company.’ IPs should be aware of the constantly evolving risks of money laundering and terrorist financing. The IPA has published some examples in the form of entirely fictional characters created to represent the types of potential money laundering threats the insolvency profession might face from potential clients prior to and during appointments. These examples are available here.

Anti-Money Laundering case studies

The IPA has published some anonymised case studies that provide examples of non-compliance with the Money Laundering Regulations by IPA members. These examples were discovered from actual inspection visits and complaints, and will be expanded as more examples come to light. In many cases, the issue was dealt with by way of an Advisory Notice (requiring the member to take remedial action) although, in some cases, the matter was considered by the IPA’s Regulation & Conduct Committee. You can access the case studies here.