Supervisory work for 2022/23

IPA Insolvency Practitioner newsletter AML Digest, November 2022

Contents

• David Holland, Chief Inspector and IPA Money Laundering Reporting Officer
• AML 2021/22 Annual Report and 2022/23 Sector Risk Assessment
• Awareness of CEO fraud and impersonation frauds
• Amendments to the 2017 Money Laundering Regulations
• SARs Reporter Booklet
• Ongoing monitoring and review of a business relationship – Reg 28(11) Money Laundering Regulations 2017
• Accountancy AML Supervisors’ Group alerts
• Sanctions
• SAR Reform Programme
• SAR Glossary Codes
• Renewals
• ISS AML training and IPA Learning

The IPA carries out AML supervisory work in three ways:

1. As part of the usual round of insolvency inspection visits
2. Specific AML visits
3. AML compliance reviews

AML visits will tend to be carried out on site and require a review of AML policies and procedures, a review of how AML is considered on a sample of cases and interviews with staff members to understand that your internal AML policies and procedures are effective.

Compliance reviews tend to be off-site and require a review of AML policies and procedures. Cases can be checked to consider how AML is dealt with, and the firm’s MLRO will be interviewed to understand how AML is dealt with at the firm.

As part of each AML newsletter, we will publish details of the visits and reviews undertaken, and any specific outcomes that members should be aware of.

For previous visits and reviews, the main topics that arose were:

• SARs policy to include details on DAML requests and recommend use of a SARs reporting form
• Training log needs to be clearer on when training has been undertaken and any score if there are questions to answer as part of the training
• Reminder to monitor AML and due diligence during life of case and consider changes to information such as change in PSC
• SARs – reminder that the MLRO does not need to carry out a full investigation to gather all information before making a SAR report – an initial suspicion sufficient to warrant a report should result in a SAR being issued and the MLRO can make a follow-up report

Advisory Notices have recently been issued to members in respect of:

• Reg 28 and carrying out CDD work prior to the establishment of a business relationship
• Ensuring that policies and procedures required under Reg 19 are in place to support the work carried out on AML and assist in the completion of checklists by the IP’s staff