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Insolvency · practitioners

Checks for everyinsolvency appointment.

Check the company and the people behind it before you consent to act, watch the case every morning after, and keep the record your licensing body asks to see.

Start from £9 a month Your duties
5 days
To finish checks after an appointment with no prior contact
£12,000
A bankruptcy asset sale that needs the buyer checked
OFSI
Sanctions reporting duty since 14 May 2025
01 · Your duties

What the rules ask, and what we do.

From the Money Laundering Regulations 2017 and the CCAB insolvency appendix (Appendix F), approved by HM Treasury.

  1. 01Reg 30 · App. F.3.3 to F.3.7

    Check before you consent to act

    Identify and verify the company or debtor, its officers and owners before you agree to act. With no prior contact, finish as soon as practicable: five working days is reasonable.

    Add the company by name or number: its details, directors and owners come from Companies House, checked in one run with the disqualified directors register. Their ID with a live selfie, by link, through Vouchsafe (on the GOV.UK register of certified services).

  2. 02Regs 28(4), 30A · App. F.3.9

    Find who owns and controls it

    A court order can evidence the insolvent’s identity, but not who owns or controls it. Identify the beneficial owners on every case.

    Owners traced to people from Companies House. A difference from what you are told comes with how to report it.

  3. 03Regs 33, 35 · sanctions rules

    Screen for sanctions and PEPs

    Enhanced checks for politically exposed persons. Since 14 May 2025 you must report a designated person or a breach to OFSI.

    UK, UN, EU and US lists and PEPs for the company and everyone behind it. You decide each possible match, with a reason.

  4. 04Reg 27(2) · App. F.3.15 to F.3.20

    Buyers, contributors and creditors

    In a bankruptcy, check a buyer of assets in a sale of £12,000 or more, and anyone paying into an estate. Check creditors against the sanctions lists before a dividend.

    Add a buyer or contributor to your register and check them like a client, before the contract is binding. Soon A creditor list screened in one go before a dividend.

  5. 05Reg 28(11) · App. F.3.12 to F.3.14

    Watch the case

    Keep monitoring on a risk basis, closely while trading continues, and update your checks when what you knew changes.

    The company re-screened against the sanctions lists every morning, and a new director or owner at Companies House picked up the same day.

  6. 06Regs 18, 19, 40

    Your firm’s risk assessment and records

    A written firm-wide risk assessment with policies that follow from it, and due diligence records kept for five years.

    Every check, decision and document kept, with an audit trail and an inspection bundle. Soon A risk assessment and policies written for insolvency work.

02 · Checks

What we check for insolvency practitioners.

Every check in every plan. Yours are lit; pick another industry to compare.

12 of 17 checks for insolvency practitioners
People2
ID and livenessBy phone link
Proof of addressDocument check
SanctionsUK, UN, EU, US
PEPPolitically exposed
Companies6
Company profileCompanies House
OwnersTraced to people
Directors' IDVerified or due
Disqualified directorsOfficial register
FCA registerAuthorised firms
InsolvencyStatus and history
Risk scoreA to F, with reasons
Trade0
US export listsEntity List and 5 more
50% ownershipListed owners
Shipment recordEvery party
Always included4
Daily monitoringEvery checked client
Signed certificateWith a verify link
Audit trailEvery action
APIREST and MCP
03 · Where the risk is

Where the risk is.

The 2025 National Risk Assessment rates money laundering risk for accountancy services, insolvency included, as high. The insolvency appendix names these higher-risk factors for an appointment.

  • Officers or owners under criminal investigation
  • Cash-flow trouble that may hide fraud
  • An insolvent that is itself a regulated business
  • Realising or distributing assets
  • Appointments you cannot resign from
  • Assets, owners or payments in high-risk countries
  • No personal contact with the directors or owners
  • Phoenix companies (NRA 2025, 3.103)

Source: CCAB Appendix F, insolvency practitioners (May 2022), paragraph F.2.3

04 · Questions

Asked by insolvency practitioners.

Who is the client in an insolvency appointment?

The company, partnership or person you are appointed over: there is always a business relationship with them (Appendix F.3.1), so they are checked before you consent to act. Buyers of assets are usually not your clients, except in a bankruptcy or trust deed.

What if there was no contact before the appointment?

Make an initial identification and risk assessment before consenting, then finish the checks as soon as practicable; within five working days is considered reasonable (Appendix F.3.5 to F.3.7). The Companies House record and our checks need nothing from a hostile management.

Can we rely on the court order?

For an appointment by the court, the official receiver or the Secretary of State, the order can evidence the insolvent’s identity. It does not show who owns or controls it, or whether money laundering took place (Appendix F.3.8 and F.3.9).

Do we check buyers of assets?

In a bankruptcy, sequestration or trust deed the assets vest in you, so a sale of £12,000 or more is an occasional transaction and the buyer is checked before the contract is binding (Appendix F.3.15, regulation 27(2); £12,000 since 30 June 2026, before that 15,000 euros). As liquidator, administrator, receiver or supervisor, the buyer is not your client (F.3.16).

Do we need to check creditors before a dividend?

They are not clients, so full checks are not required. But making funds available to a designated person is prohibited, so check recipients against the sanctions lists before a distribution (Appendix F.3.20).

What must we report, and to whom?

Since 14 May 2025 insolvency practitioners must tell OFSI as soon as practicable if they know or suspect someone is a designated person or has breached sanctions. Suspected money laundering goes to the National Crime Agency, with a defence request before you deal with property you suspect is criminal (Appendix F.6).

Who supervises us for money laundering?

The body that authorised you as an insolvency practitioner (Appendix F.7.1), such as ICAEW, the IPA or ICAS. They point to the CCAB guidance and its insolvency appendix, both approved by HM Treasury.

Start with your open cases.

Add each company or debtor and run its check: it is then watched every morning, with a reminder to check it again each year.

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