Russian sanctions reminder

IPA Insolvency Practitioner newsletter, July 2022

Contents

• Paul Smith, CEO
• Samantha Keen, President
• AML case studies
• Committee for Advertising Practice Enforcement Notice reminder
• HMRC update
• Don’t miss our final four Roadshows for 2022 this autumn…
• The IPA Awards Reception
• Personal Insolvency Conference – take advantage of earlybird rates for a limited time only!
• Exclusive discounts on training from the IPA and our partners – make savings on essential CPD
• Pride is about more than just rainbows – it’s about radical change
• Vacancy: Lay member of the IPA Anti-Money Laundering Committee
• Need new IT products? Claim exclusive IPA membership offers from Dell
• CPI training with BPP – special offer for IPA members (member login required to view)
• Insolvency Insider industry update

Details were provided in the March newsletter and May newsletter on the need for members to fully understand assets under the ownership and control of clients and the impact on any insolvency appointments. New sanctions against Russian and Belarussian individuals and corporations continues to rise, and the position is fast-moving. It is therefore essential that that your Customer Due Diligence (CDD) policy includes checking for updated sanctions and that checks are carried out not only on new appointments, but where payments are due to be made to charge-holders, creditors and shareholders.

Members should also remember to report to the Office of Financial Sanctions Implementation (OFSI) any knowledge or suspicion of a breach of financial sanctions and should remember that reports to OFSI are not Suspicious Activity Reports (SARs). It is likely that where you are reporting a known or potential sanction breach, you will also need to lodge a SAR with the National Crime Agency. The March newsletter article provided links to guidance from the Consultative Committee of Accountancy Bodies (CCAB) and HMRC, and links to the OFSI website.