The Isle of Man Government and the Isle of Man Financial Services Authority (“the Authority”) are committed to continually reviewing the Island's legislation and regulations against the recognised international standards. For details of the Isle of Man Government’s commitment to combating Money Laundering and the Financing of Terrorism and Proliferation please see the following link.
Also, the Isle of Man Government has published a national strategy in relation to its stance against money laundering and the financing of terrorism. This document sets out priority goals actions identified following a review of existing defences. The document can be found here.
AML/CFT Working Groups / Meetings
Following the 2008 / 2009 Financial Sector Assessment Programme (“FSAP”) evaluation report on the Isle of Man , the Isle of Man Government established an AML/CFT Strategic Group responsible for overseeing AML/CFT developments at a high level and at which the Authority is represented. Following a review in 2016, the Strategic Group was re-formed as the Financial Crime Strategic Board. In addition, the Authority co-chairs the AML/CFT Technical Group with the Isle of Man Gambling Supervision Commission. This group is made up of representatives from various government departments and statutory boards and is responsible for progressing the Island’s response to the recommendations made by international assessors such as the IMF and MONEYVAL and also to consider international standards such as the FATF Recommendations and Methodology. The AML/CFT Technical Group reports into the Financial Crime Strategic Board. These groups are also involved in the development of the Island’s National Risk Assessment.
The Authority is also a key member of the AML/CFT Advisory Group which is a group consisting of representatives both from Government and industry bodies set up to facilitate dialogue on AML/CFT matters. This advisory group has been used extensively in the consultation process for AML/CFT legislation.
The Authority, with the Attorney General’s Chambers and the Financial Intelligence Unit, also participates in meetings held with the authorities of Jersey and Guernsey to discuss AML/CFT matters of mutual interest.
National Risk Assessment
In February 2012, the FATF issued the revised FATF Recommendations which included a new recommendation which required jurisdictions to undertake a national risk assessment (“NRA”).
The FATF explained that the standards were revised to strengthen the requirements for higher risk situations, and to allow countries to take a more focused approach in areas where high risks remain or implementation could be enhanced. However, in order to do this countries should first identify, assess and understand the risks of money laundering and terrorist financing that they face, and then adopt appropriate measures to mitigate the risk. This risk based approach is considered to allow countries to adopt a more flexible set of measures, which are compliant with international standards, in order to target their resources more effectively and apply preventative measures that are commensurate to the nature of risks in order to focus their efforts in the most effective way.
The Isle of Man conducted its NRA process between October 2014 and June 2015 using the World Bank self-assessment tool. The process began with information gathered from Government and industry in the summer of 2014 ahead of a first workshop with the World Bank in November 2014. Between November and April several working groups conducted threat and vulnerability assessments at both national and sector level. A final workshop then took place in April 2015 to review the NRA and the identified actions arising from the work.
The NRA was published in 2015 and updated in 2020, the most recent document can be found here.
For further information please see the dedicated webpage on the Cabinet Office’s website