General guidance

Anti-Money Laundering compliance is important to avoid a supervisory authority’s regulatory and disciplinary processes, but it is also an important aspect of public protection. The IPA carries out its regulatory duties with due regard for the public interest, and that includes effective and robust AML supervision.

The IPA publishes a wide range of resources to help its members to achieve compliance as effectively and efficiently as possible. In other sections of the AML Hub, you will find information to help you assess AML risk, report suspicious activity and conduct an AML compliance review. In this section, you will find guidance produced by the IPA specifically for its members, as well as other guidance produced by way of collaboration between professional bodies.


Anti-Money Laundering guide for members

This guidance is designed to assist IPs in understanding what is expected of them under the Money Laundering Regulations. It is intended to support the insolvency appendix to the CCAB Guidance (see below). This IPA guidance should not be regarded as formal regulatory guidance or legal advice.

Much of the guidance covers matters that apply to all relevant persons. However, there is also a chapter that specifically considers issues that arise in relation to insolvency work. Members should continue to seek assistance from their own compliance teams and colleagues who deal with AML matters, where appropriate.

The guidance is available here. Information is available elsewhere on the IPA website that sets out what the IPA’s Monitoring Inspectors may expect to see when undertaking regulatory visits to members’ firms.


CCAB guidance

The Consultative Committee of Accountancy Bodies (CCAB) publishes AML Guidance for the Accountancy Sector (AMLGAS), which now includes an appendix containing supplementary guidance for IPs. The initial guidance was produced in 2017, and it was updated in 2020. The latest version of the Guidance is available here. It incorporates changes to the Money Laundering Regulations introduced through the implementation of the 5th Money Laundering Directive (the new legislation came into force on 10 January 2020).

AMLGAS covers Anti-Money Laundering and counter terrorist financing, and is intended to be read by anyone who provides audit, accountancy, tax advisory, insolvency or trust and company services in the United Kingdom. Among other things, it includes guidance on taking a risk-based approach, carrying out customer due diligence, Suspicious Activity Reports (SARs) reporting, record keeping, training and maintaining awareness.

The 2020 draft guidance is pending approval from HM Treasury, but we would expect IPA members to pay due regard to this guidance. Members who practise within firms supervised by other supervisory authorities must also take account of any relevant guidance issued by those authorities.

Click here to access the complete suite of AMLGAS, including the latest appendices (see below).


CCAB guidance for Insolvency Practitioners

Shortly prior to updating the main AMLGAS, the CCAB bodies produced an appendix to the guidance specifically aimed at IPs. Like the main document, this appendix (along with an appendix for use by tax practitioners) remains in draft, awaiting approval by HM Treasury. Nevertheless, the IPA would expect members to pay due regard to the guidance in this draft appendix.

Click here to access the complete suite of AMLGAS, including the latest appendices and some useful explanatory notes.


CCAB Economic Crime Manifesto

The CCAB launched its first Economic Crime Manifesto in 2016 with the key aim of improving the effectiveness and capabilities of AML in the UK. Further details of the CCAB 2016 Economic Crime Manifesto may be found here. The CCAB issued a second Manifesto in 2021, setting out areas for change. The 2021 Manifesto is available here.


AASG AML Supervision Flowchart

The IPA is a member of the Accountancy AML Accountancy Supervisors Group (AASG), which has published a flow chart to assist IPs, accountants and other professionals working in financial roles in any consideration as to which authority may supervise a firm for AML purposes. The flow chart can be downloaded here.