IPA Insolvency Practitioner newsletter AML Digest, April 2026
| Compliance Issue | What do we see? | Tips on effective compliance |
| Proliferation Financing (PF) – Reg 18A | Firms are not including a consideration of the risks from PF as part of the Firm Wide Risk Assessment (FWRA). Remember – the IPA advises PF is low risk for insolvency work, but there may be heightened risks if an appointment is taken in a relevant industry | Consider work undertaken by the firm – note any cases where the trade was in a relevant industry Ensure that your Reg 18/18A FWRA includes a note on PF and highlights industry types that may carry a heightened risk Highlight relevant industries where cases where appointments were taken as higher risk Circulate any changes to the FWRA and discuss with staff |
| Policies/Procedures – Reg 19 MLR17 | Policies are incomplete and not regularly reviewed Remember – getting policies/procedures ‘right’ means any updates or amendments should be relatively minor | Ensure that you hold policies as required under Reg 19/19A Include a review date and ensure that these are regularly checked to ensure the remain effective Circulate any changes and discuss with staff |
| Customer Due Diligence (CDD) | Not picking up high-risk areas and/or not recognising higher risks outlined from CDD information and use of CDD checklists Remember – file notes as per the Insolvency Practitioners (Amendment) Regulations 2015 – Reg 3 | Ensure your CDD policy is clear on what is required Ensure your CDD policy also highlights when Enhanced Due Diligence must be undertaken and what this may entail Ensure that your AML assessment includes a conclusion regarding the information obtained – especially if you consider the risk is not ‘high’ but is ‘normal’ |
| AML training | No AML training log to evidence training undertaken No MLRO training Effectiveness testing Remember – ensure these matters are included in a training policy for the firm | Ensure that you have a training log which provides details of: Date of training; Who attended; Scope of the training; Any test score Ensure that the log captures training to new joiners or staff returning after a prolonged absence as well as any staff who missed a training session Ensure that your MLRO receives regular training – as required – on their role – and especially when a new MLRO is appointed Test the training – have spot tests or discuss in team meetings – this will highlight any areas where refresher training may be needed |
| Defence Against Money Laundering (DAML) requests | Ensure details of DAML requests are included in your office Suspicious Activity Reports (SARs) policy Remember – the de minimis level for DAMLs was increased last year to £3,000 – so any sum reported below that level does not need a DAML request | Ensure that your SARs policy includes details on DAMLs: What they are; when they may be required; time limits for approval by the NCA; what if consent is not provided; what can be carried out on the relevant case whilst a DAML request is with the NCA |