SAR reporting

IPA Insolvency Practitioner newsletter AML Digest, April 2023

Contents

• David Holland, Chief Inspector and IPA Money Laundering Reporting Officer
• High-risk countries for money laundering purposes: Enhanced Due Diligence
• Proliferation Financing
• Ongoing monitoring of AML matters in an appointment
• Licences from OFSI
• Insolvency Practitioner identity fraud and scam websites
• Reporting misuse of bounce back loans
• NCA Amber Alert: High Net Worth Individuals and Tax Evasion (member login required to view)
• AASG alerts (member login required to view)
• Regulation 18 risk assessment reviews
• Reporting of material discrepancies of Companies House records
• Economic Crime Levy
• OPBAS Sourcebook
• How the 2017 Money Laundering Regulations have evolved
• ISS AML training
• OFSI webinar

As insolvency work is a regulated sector for money laundering purposes, members should be aware of the requirement under the Proceed of Crime Act 2002 (POCA) for firms’ Money Laundering Reporting Officers (MLROs) to make Suspicious Activity Reports (SARs) to the National Crime Agency (NCA) when the MLRO is advised of knowledge or suspicions of activity that may indicate money laundering.

This is an important duty in assisting the NCA in the collation of intelligence that assist with combating money laundering and criminal activity. As a reminder, the IPA as an AML Supervisory Authority has the ability to review the submission and content of SARs by firms we supervise for AML purposes. If your firm is supervised by another AML Supervisory Authority, that authority also has the right to review SARS (contained in S333D POCA & S66 of the 2017 Money Laundering Regulations (as amended)). The NCA have published an updated guidance note on SARs which includes best practice on SARs submission. The guidance can be found here.