"Client ID" - how does it work in insolvency situations?
A look at what you need to do, as a licensed Insolvency practitioner, to comply with the identification requirements of the money laundering regime.
Most ICAEW licence holders undertake their insolvency appointments within the context of a practice, be it a general or insolvency practice. Where you are surrounded by insolvency specialists there may be clarity and shared understanding of how the money laundering client identification requirements apply in an insolvency context. However if you operate within a general practice and/or your MLRO has limited understanding of insolvency relationships, confusion can creep in.
This article sets out the requirements in a specific insolvency context and aims to address some of the uncertainties which may still exist.