Sanctions and AML/CFT thematic project

The Isle of Man Financial Services Authority (“the Authority”) is preparing to roll out a thematic project focusing on AML/CFT compliance in relation to sanctions.


The Authority’s AML/CFT Supervision Division will lead the initiative, working in conjunction with the Authority’s other supervisory divisions where appropriate.


This thematic, which is scheduled to commence later this week, will focus on certain elements of the Anti-Money Laundering and Countering the Financing of Terrorism Code 2019 (“the Code”). The initial phase of the project will involve a questionnaire that will be issued to all relevant entities using the Authority’s new AML CFT Risk Analysis system, STRIX.


In Phase 2 of the project, requests for relevant documentation to be provided to the Authority will be sent to relevant licence holders and designated businesses. This will occur at the same time as they are notified of their inclusion within the second phase of the project. The nature and scale of the thematic project means that notifications, and the involvement of individual licence holders and designated businesses, will be staged over a period of time.


Further assistance and guidance in relation to the Code is available on the Authority’s AML/CFT webpage. Useful documents include, but are not limited to, the Anti-Money Laundering & Countering the Financing of Terrorism Handbook, guidance issued by the IOM Customs & Excise Customs & Excise Sanctions Guidance, and the latest IOM  Financial Crime Strategy 2024 -2026.


Ian Spence, Head of the Authority’s AML/CFT Supervision Division, said:  ‘The Island is committed to fulfilling its international obligations with regard to:

  • sanctions regimes, and denying terrorist groups access to the financial system;
  • countering the proliferation of weapons of mass destruction; and
  • effective controls on the export and trade in military equipment, dual-use items, and other goods of concern.’


He added: ‘The importance of awareness relating to both financial and non-financial sanctions is long established in AML/CFT legislation, albeit additional focus has arisen in the last two years as a result of global conflict,  including the invasion of Ukraine and elsewhere.


‘The thematic presents a great opportunity to test and evidence how relevant persons are meeting their AML/CFT challenges in this area. In addition to increased engagement with firms during the project, we hope to discover and highlight some best practice that can be shared and fed back with the industry.


‘The project will add to the Authority’s wider AML/CFT evidential understanding and picture of risk, building on the work the Authority has recently seen with the foreign PEP, TCSP BRA, and accountancy profession CRA thematic projects.’