Do insolvency practitioners have to do sanctions checks before taking an appointment?

Yes. Since 14 May 2025 insolvency practitioners are "relevant firms" under UK financial sanctions, so you must report to OFSI as soon as practicable if you know or have reasonable cause to suspect that a person is a designated person or has breached the sanctions. The Money Laundering Regulations 2017 apply too (regulation 8(2)(c)): you must verify the client, and anyone who owns or controls a company client, before the business relationship starts (regulation 30). The IPA expects that before any letter of engagement and before money reaches your client account.

What to check before you consent to act:

• The company against the UK Sanctions List, and the UN, EU and US lists where it has international links.
• Every director and owner, following the ownership recorded at Companies House through each holding company. A company owned or controlled by a designated person counts as sanctioned too (OFSI's ownership and control test).
• PEP and adverse media on the people who own and run it, so the risk assessment has the facts.
• A buyer in a pre-pack. A sale of all or a substantial part of the business to a connected person in the first eight weeks of an administration needs creditor approval or an evaluator's report (the Administration (Restrictions on Disposal etc. to Connected Persons) Regulations 2021), so compare the buyer's directors and owners with the company's.

During the case: check creditors before a distribution. Paying a designated person is making funds available to them, which needs an OFSI licence. Lists change daily, so a creditor who was clear at appointment may not be clear at the dividend.

If there is a match: don't deal with the person's money or assets, report it to OFSI, record it with your nominated officer and treat the appointment as higher risk, with enhanced due diligence and regular review. Keep the records for at least five years (regulation 40).

Work that is not insolvency practitioner business, such as acting as a receiver in the sale of a property, is outside the sanctions reporting duty.

On Certaby the pre-appointment check is £12.99 a company: the company's sanctions screen with adverse media, the company and owners check, PEP and adverse media on every director and owner it finds (up to 30), the register of disqualified directors and, with a buyer, a connected-party comparison. Creditors can be screened before a dividend at 99p a name.

Source: OFSI: financial sanctions guidance for insolvency practitioners

Last updated 2026-10-09.