OPBAS – Supervisory Report 2022/23 and the Supervisory Regime consultation

IPA Insolvency Practitioner newsletter AML Digest, September 2023

Contents

• David Holland, Chief Inspector and IPA Money Laundering Reporting Officer
• Spotlight on AML and Fraud (CPD: 5h)
• Reminder: High-risk countries for money laundering purposes: Enhanced Due Diligence
• Proliferation Financing
• New SARs Glossary Code & Reporting Routes Guidance
• The Economic Crime (Anti-Money Laundering) Levy (Amendment) Regulations 2023
• SARs in Action
• Updated guidance on submitting better quality Suspicious Activity Reports
• AASG/NCA alerts
• Regulatory update for Insolvency Practitioners: Importance of reviewing updates to the OFSI Sanctions List
• AML supervision
• The Insolvency Practitioners (Amendment) Regulations 2015 – Regulation 3
• New SARs Reporter Booklet

Members will recall that OPBAS is the oversight regulator of the AML Supervisory Authorities. Currently, the AML and CTF supervisory system is made up of three statutory supervisors – the Financial Conduct Authority, the Gambling Commission and HMRC – and 22 professional body supervisors (PBSs) who supervise the legal and accountancy sectors.

OPBAS regularly publish reports on the progress and themes from the supervisory work of the 22 PBSs, and their report covering 2022/23 was published in April 2023. A link to the report can be found here.

The report is also available to be viewed in the Anti-Money Laundering section of the IPA website, under the ‘IPA as a Supervisory Authority’ tab.

HM Treasury has also published a review and consultation on AML/CTF Supervision.  The 2022 Review of the UK’s AML/CTF regulatory and supervisory regime concluded that while there had been continued improvement to the regime, some weaknesses in supervision may need to be addressed through structural reform. The Review sets out four possible models for a future AML/CTF supervisory system.

HM Treasury’s open consultation on Reforming AML & CTF supervison was published on 30th June 2023. The consultation will be open for three months, closing on 30th September 2023. The four models proposed by HM Treasury have significant implications for supervision, costs and legislative requirements and members are encouraged to consider the potential impact to their firms.