Updated guidance published to support AML/CFT Statistical Return

The Isle of Man Financial Services Authority has published updated guidance to assist Island firms in responding to the upcoming AML/CFT Statistical Return (“the Return”).

 

Several changes have been implemented to enhance the Return, which will be issued on Monday 5 January 2026 to capture the year-end data for 2025 ahead of the new submission deadline of 3 April 2026.

 

The revised guidance reflects positive collaboration with a focus group of stakeholders and provides all regulated entities and designated businesses with an insight into the questions and requirements of the 2025 Return.

 

Sections in the guidance document coloured in green indicate a new or significantly changed question. The Authority is continuing to assess industry feedback, so the guidance may be subject to further amendment during the reporting period.

 

Once the Return is issued on 5 January, a dedicated team of officers will be in place to assist users and respond to any queries. Further information about the STRIX data collection and analysis system is available on the Authority’s website.

 

As a data-driven regulator, it is essential for the Authority to work with the most accurate and up to date information possible. With that in mind, firms are encouraged to complete the 2025 Return at the earliest opportunity.

 

Key Changes

  • Money transmission entities, Insurance Intermediaries, Estate Agents & Virtual Asset Service Providers (VASPs) are being asked some separate questions to enable a more granular view on types of customers. While these are shown as ‘new’ questions within the guidance, they are replacement rather than additional questions.
  • Following industry feedback, more categories are available for the customer types under TCSPs, with additional questions around Nominee Shareholding & Registered Office services.
  • SNPOs are being asked fewer questions, with relevant language being used for Donor/Beneficiaries.
  • Commercially Exposed Persons (CEP) guidance and data collection has been updated and is more focused following industry feedback.
  • Questions regarding firms that utilise banking facilities have been amended to enhance the Authority’s understanding of financial flows in and out of the jurisdiction.
  • Exempted transactions and Transfer of Blocks of Business questions have been updated to assist the Authority in understanding who is using the exemptions available under the Code.
  • Two data points have been added around controls, which will enable the Authority to gain an insight into Full Time Equivalent (FTE) compared with head counts in firms, and the points of business acceptance.
  • Changes in ‘flow’ and descriptions – users will see better placement of text and guidance to ease the use of the Return.

 

David Baker, Senior Manager at the Authority’s AML/CFT Supervision Division, said: “The input by industry has made a significant contribution in this year’s AML/CFT Annual Statistical Return and the guidance. The Return itself marks a continued commitment to the Authority’s risk-based approach to supervision, as it provides critical information to inform the engagement into 2026 and 2027. If you have any questions, comments or feedback, please contact us at your earliest opportunity at amlreturns@iomfsa.im”