The Compendium

the business’s client files and business information to enable them to make the required decisions on the basis of all information held by the business.

The MLRO will report any suspicions of money laundering or other financial fraud and the decision to report, or not to report, must not be subject to the consent of anyone else. The MLRO will report such suspicions to the National Crime Agency (NCA).

[See ‘Insolvency Practitioner’, ‘Anti-Money Laundering’, ‘National Crime Agency’ and ‘NCA’.]

Money Purchase Pension

A money purchase pension plan is an employee retirement benefit plan that resembles a corporate profit-sharing programme. It requires the employer to deposit a set percentage of the participating employee’s salary in the account every year.

[See ‘Stakeholder Pension’.]

Monitor

A ’Monitor’ will be appointed in a Moratorium under the Corporate Insolvency and Governance Act (CIGA) 2020. This is an Insolvency Practitioner who oversees the process and must bring the Moratorium to an end by filing a notice at court if she thinks that:

• The CIGA moratorium is no longer likely to result in the rescue of the company as a going concern;
• The objective of rescue has been achieved;
• She is unable to carry out their functions as the directors have not provided them with the relevant information;
• The company is unable to pay moratorium debts which have fallen due or pre-moratorium debts for which the company does not have a payment holiday.

However, responsibility for the day-to-day running of the company remains with the directors (a ‘debtor-in-possession’ procedure).