Transfer of appointments

IPA Insolvency Practitioner newsletter AML Digest, December 2023

Just a reminder that where there is a transfer of an appointment to you (not a hostile appointment, but where the transfer is due to the resignation, retirement etc. of the former office-holder(s)), you should ensure that you carry out an assessment of the AML risks to the case and carry out relevant due diligence work.

It may be that on the transfer, the former office-holder is happy to provide the documents they utilised for their due diligence work to allow a swifter consideration that you are content with the information and can adequately assess the risks.

However, you should be alive to cases where you have no provided prior due diligence and may have to request relevant documentation to complete due diligence work. Ensure that clear file notes are held of the position, work being undertaken to complete due diligence and conclusions reached.