The Beautiful Pour… More than Just AML

1 July 2026

Ben Luxford, Technical Lead, IPA

Pouring Guinness is an almost sacred ritual, a testament to the respect and reverence the public have for this iconic Irish stout. The beautiful pour enhances the entire drinking experience, turning a simple pint into a symphony of flavour, texture and tradition. Some publicans have lost punters for failing to follow this ritual.

Mastering the Guinness pour is a rite of passage for a publican. Insolvency Practitioners (IPs) must similarly master their Anti-Money Laundering (AML) responsibilities under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs). While the former creates the perfect head, the latter protects the integrity of the UK financial system.

Common Mistakes to Avoid While Pouring Guinness

According to Guinness, many eager pourers falter on their quest to the perfect pint of black gold. The common mistakes are:

Pouring too quickly, not allowing for the proper ‘surge and settle’ time
Underfilling or overfilling the glass
Having the wrong temperature

Common Mistakes to Avoid When Following AML Requirements

The common mistakes in pouring mirror the simple failings with AML requirements.

1. Pouring Too Quickly – Rushing the Onboarding

2. Underfilling or Overfilling – Misjudging the Risk

3. The Wrong Temperature – Outdated Information

Taking each mistake in turn…

(1) Rushing the Onboarding

Insolvency proceedings are often a target for those seeking to layer (‘clean’) illicit funds or hide assets. For an IP, AML compliance is not just a regulatory box to tick – it is a critical defence mechanism against this type of action. Therefore, accepting an appointment or funds before completing Customer Due Diligence (CDD) is like pouring a pint of Guinness too quickly; you just do not do it. An IP must verify the identity of the client and the Ultimate Beneficial Owner (as defined by Financial Action Task Force (FATF)) prior to appointment. Rushing this stage to secure the case may potentially lead to ‘cloudy’ compliance that will likely be picked up during an IPA monitoring visit.

(2) Misjudging the Risk

Underfilling or overfilling a pint of Guinness may result in a messy pint and jeers from publicans. Applying a one-size-fits-all approach to AML, rather than a risk-based approach, may similarly result in a messy appointment and regulatory action. ‘Underfilling’ happens when an IP relies solely on a basic electronic ID check without investigating the source of funds or addressing other relevant risks identified. ‘Overfilling’ happens when IPs waste hours on low-risk local cases while ignoring high-risk triggers. Effort must be proportionate (the size and nature of business) to the risks identified in an IP’s risk assessment – reg.18 ‘Risk assessment by relevant persons’.

(3) Outdated Information

Serving a pint of black gold too warm or too cold may leave an unwanted aftertaste. Working off outdated template documents or overlooking new high risks is also likely to leave a long-term unwanted aftertaste too. Keeping up to date with regulatory, risk changes and lists published by the FATF [1] is essential, as is using the UK Sanctions List Search Tool. If the ‘temperature’ is not right, or your information is not up to date, both frameworks are at risk of failing.

A Clean Glass

Just as a publican looks for a clean glass, an IP must look for ‘clean’ transactions. Any smudges on an insolvency ‘glass’ should be red flags for an IP. These usually come from unusual assets in the form of cryptocurrency, tokens or luxury goods acquired before insolvency, or opaque transactions, or a director too desperate to settle debts with untraceable third-party funds. IPs should remain alert to them.

Making AML Efficient – The Risk-Based Approach

Efficiency comes from structure, not shortcuts.

Quality over Quantity: Focus training on real-world insolvency red flags, rather than generic slides.
Standard Templates: Use consistent checklists for Reg 18 (firm-wide) and Reg 28 (case-specific) assessments.
Clear Escalation: Staff must know exactly when to alert the MLRO.
SARs Reporting: Suspicion (not proof) is the threshold. Use the National Crime Agency (NCA) portal immediately when a red flag is confirmed, and remember: do not tip off the subject.

Remember that a good barrel of Guinness can still result in a bad pint, if poured by badly trained bar staff. It’s the same for AML training and awareness – having a good system in place only works if all relevant employees are trained in its use.

Suspicious Activity Reporting

If you have a suspicion (more than a mere inkling, but less than proof) that funds are the proceeds of crime, you must file a Suspicious Activity Report (SAR) via the National Crime Agency (NCA) portal. Reports should be made as soon as the suspicion is formed. And remember that, whilst you can tell a publican they have poured wrong, it is a criminal offence to inform the subject that a SAR has been filed.

Record-Keeping

Under the MLRs, you must retain AML records for five years after the end of the business relationship or the completion of the transaction. This includes your rationale for risk ratings and evidence relied upon for CDD.

One for the road.

The new Money Laundering and Terrorist Financing (Amendment) Regulations 2026[2] introduces several key changes affecting the insolvency profession, most notably a new provision (reg.30ZA) regarding insolvent bank customers. This allows credit institutions to open accounts and permit transactions for customers of an insolvent bank under the Banking Act 2009 before completing full CDD, provided it is finished as soon as practicable. Additionally, firms dealing with trusts must review updated provisions and de-minimis limits regarding the Trusts Registration Service (TRS), and all businesses must update their policies to reflect the transition of monetary thresholds from Euros to British Pounds (GBP).

Compliance frameworks must also be adjusted to reflect refined risk triggers and due diligence requirements. The automatic trigger for Enhanced Due Diligence (EDD) regarding high-risk third countries has been narrowed strictly to jurisdictions subject to a FATF “Call to Action,” though continued vigilance is required for countries under increased monitoring. Furthermore, the EDD trigger for complex transactions has been redefined from “complex and large” to “unusually complex or unusually large,” requiring a review of procedural thresholds. Finally, IPs operating pooled client accounts face stricter obligations to proactively assess, manage and mitigate money laundering risks associated with the customers using those accounts.

For further information about these regulations, please click here.

Last orders, please.

Just as you would not pour a pint of Guinness into an ale jug, the component parts of an AML system should have a joined up and complementary approach. One inappropriate element in the system can let the whole process down.

The art of pouring a beautiful pint of Guinness is a fascinating blend of skill, patience, tradition, and yes, a bit of Irish magic – no rushing and no skipping steps. Whilst good AML compliance may not be as beautiful, it is not optional; an IP is obliged to comply with AML requirements, and it is an important part of an IP’s work. And it may give you just as much satisfaction. So, no rushing and no skipping steps.

[1] The Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) Regulations 2024

[2] Money Laundering and Terrorist Financing (Amendment) Regulations 2026