Has your practice carried out a firm wide risk assessment?
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR17) require firms providing accountancy, trust or company services to take appropriate steps to identify and assess the risk that they could be used for money laundering, including terrorist financing. This risk assessment needs to be documented.
HM Treasury’s National Risk Assessment for 2017 identified insolvency services as one of five areas that pose the highest risk of exploitation for money laundering. Insolvency practitioners need to carefully consider and assess the risks their firm faces and design mitigating actions to address those risks.
If you deal with formal insolvency appointments, you will need to ensure your firm has addressed this as insolvency appointments fall within the definition of accounting services.