Anti-Money Laundering Strategy

Click here to download our Anti-Money Laundering Strategy.
Anti-Money Laundering Guide for Members
Click here to download our Anti-Money Laundering Guide for Members.
Anti-Money Laundering
The 2017 Money Laundering Regulations introduced the concept of the ‘Professional Body Supervisor’ (‘PBS’) who are responsible for supervising their members on compliance with the 2017 Regulations. The IPA is a listed PBS and has increased responsibility for the monitoring and review of members compliance with the Regulations in their insolvency and advisory work.
The IPA participates in external committees on Anti-Money Laundering and supports the Governments ‘Flag-it-up’ campaign to raise awareness of Money Laundering. The IPA has a dedicated page on the web-site dealing with Money Laundering which includes information and guidance to members and the public and a helpline email where questions and concerns can be raised anonymously and in confidence.
Anti-Money Laundering Regulation
The 2017 Money Laundering Regulations introduced new requirements to tackle money laundering, replacing the 2007 Money Laundering Regulations. The regulations require all individuals that provide insolvency services to be supervised for compliance with the regulations by a supervisory authority; the IPA is recognised as a supervisory authority for supervising the compliance of IPA members.
The regulations mean that any insolvency practitioner who is involved with money-laundering, even if accidentally, can possibly lose their licence, receive a fine, or face criminal prosecution.
It is therefore vital that IPA members are aware of the importance of reporting concerns around money laundering as soon as they might come across them, including submitting Suspicious Activity Reports. To help members comply with the regulation, the IPA has produced information and guidance (see below). The IPA will be publishing further information and guidance shortly.   
The IPA is also delighted to work with the Home Office and National Crime Agency to support its Flag it up money laundering campaign to promote best practice in anti-money laundering compliance and reporting suspicious activity.

Should an IPA member have any questions regarding AML compliance, please contact us via

Information and guidance

Whistle blowing guidance
Insolvency Practitioners (‘IPs) have a duty under Statement of Insolvency Practice 1 (‘SIP1’) to report any IP who is not complying, or not complied with, any relevant laws and regulations to the complaints gateway or to their relevant RPB (p4 of SIP1).  IPs also have a duty to report IPs who are not complying, or have not complied with, or have allegedly breached AML regulations and the IPA acts as a Professional Body Supervisor (‘PBS’) under Money Laundering Regulations. 

The IPA’s policy on whistleblowing can be found here.

2018 CCAB (Consultative Committee of Accountancy Bodies*) guidance
This guidance is based on the law and regulations as of 26 June 2017 and was adopted by the IPA in 2018. It covers the prevention of money laundering and the countering of terrorist financing. It is intended to be read by anyone who provides audit, accountancy, tax advisory, insolvency, or trust and company services in the United Kingdom and has been approved and adopted by the IPA.
Guidance is provided on: taking a risk based approach; carrying out customer due diligence; SARs reporting; record keeping; training and awareness.
See the guidance here.
*CCAB has five members - ICAEW, ACCA, CIPFA, ICAS and Chartered Accountants Ireland - and provides a forum for the bodies to work together collectively in the public interest on matters affecting the profession and the wider economy.
IT Security Policy
This policy deals with security of data and protection of data and information by the IPA. The policy will allow for anonymity of whistleblowers to be retained and for the IPA to meet its obligations as a Professional Body Supervisor under the 2017 Money Laundering Regulations.
Tax evasion and fraud
Should members have concerns about tax fraud and evasion please visit HMRC’s website here or call their fraud hotline on 0800 788 887.

AML complaints policy
As a supervisory body, the IPA is required to consider complaints under the Money Laundering Regulations. The IPA’s policy for AML complaints can be found here. This policy is in addition to the IPA’s complaints policy for insolvency complaints which can be located on our web-page on the ‘Complaints Guidance’ page.
Members can also write to us anonymously with any complaints about AML issues via
Conflicts policy
Any member of an IPA committee (who is an IPA member representative or a lay member), or acts in relation to any matter that related to, or arises from Committee work is required to consider if they have any conflict in relation to any business that the relevant Committee will be dealing with. A conflict not only covers the considerations in relation to insolvency matters, but also in relation to AML issues. A copy of the conflict policy can be found here and each Committee member – and any new Committee members – will be asked to sign a copy of the policy.
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