Anti-Money Laundering and Countering the Financing of Terrorism (Amendment) Code 2018

The Anti-Money Laundering and Countering the Financing of Terrorism (Amendment) Code 2018 (‘the Amendment Code’) was signed on 13 September 2018 and came into effect on 14 September 2018.

This Amendment Code gives effect to recommendations made in the Mutual Evaluation Report issued by MONEYVAL following its Fifth Round Mutual Evaluation of the Isle of Man. 

The main additions to the Anti-Money Laundering and Countering the Financing of Terrorism Code 2015 contained within the Amendment Code are:

  • The introduction of requirements to establish, maintain and operate procedures in relation to sanctions screening;
  • The introduction of the need to consider whether the relevant person has met the customer in the course of business when conducting business and customer risk assessments;
  • The introduction of Paragraph 10A which places requirements on a relevant person to undertake certain considerations where an introducer is assisting with the customer due diligence process;
  • Expansion of the requirements of Paragraph 21 to address recommended actions from MONEYVAL; and,
  • Amendment of Paragraph 23 to ensure that it only deals with instances where a relevant person places reliance on an eligible introducer.

A copy of the Amendment Code can be found here. A tracked changes version of the full Anti-Money Laundering and Countering the Financing of Terrorism Code 2015 (as amended) and an updated version of Appendix A of the Anti-Money Laundering and Countering the Financing of Terrorism Handbook are now available.

The Authority would like to thank everyone who participated in the consultation regarding the Amendment Code. Following comments received a number of changes were made to the draft Amendment Code with a view to providing further clarity of the new provisions. The responses received also indicated a number of areas were further guidance is required to assist firms in applying the new provisions to their business. This work has begun and an updated version of the Anti-Money Laundering and Countering the Financing of Terrorism Handbook will be issued in due course.

If you have any queries please contact the AML Unit by emailing aml@iomfsa.im