AML/CFT Policy Office

In 2016 the Isle of Man published the Anti-Money Laundering (AML) and Combatting the Financing of Terrorism (CFT) National Strategy 2016-2018. The Strategy was based upon the island’s 2015 National Risk Assessment of money laundering and terrorist financing. Following the publication of the Strategy, the Chief Secretary established a central AML/CFT Policy Office to act as the co-ordinating body for the Isle of Man Government’s AML/CFT regime across all law enforcement authorities and regulators.

The AML/CFT Policy Office predominately steers Isle of Man engagement with two key international organisations:

• The Financial Action Task Force (FATF), an independent standard-setting body that leads the international fight against money laundering and terrorist financing, through the implementation of the 40 FATF Recommendations.

• MONEYVAL, a Council of Europe committee that oversees the implementation of the standards set by the FATF for many European countries, including the Isle of Man.

In 2016, the Policy Office acted as the lead authority for coordinating the on-site visit to the island of a delegation of the Council of Europe's Committee of Experts (MONEYVAL) for the evaluation of the Isle of Mans Anti-Money Laundering and the Financing of Terrorism measures. The findings of that assessment were published in the Fifth Round Mutual Evaluation Report of the Isle of Man (MER). The report analyses a countries’ level of technical compliance with the 40 FATF Recommendations and the level of effectiveness of the Isle of Man’s AML/CFT Regime.

Contained within the MER are numerous recommended actions on how the Isle of Man can improve its regime so that it more fully meets the international standards set out by the FATF on Combating Money Laundering and the Financing of Terrorism and Proliferation. The Policy Office acts as the main conduit between the Isle of Man Government and the relevant international bodies, notably MONEYVAL, to ensure that recommendations arising out of international assessments and the priority objectives identified in the Isle of Man Governments Financial Crime Strategy, are fully considered, addressed and implemented.

As well as ensuring that the Isle of Man meets its international obligations, the Policy Office works closely with IoM law enforcement, the Financial Intelligence Unit, Customs and Excise, the Attorney General Chambers, the IOM Financial Services Authority and Gambling Supervision Commission to identify emerging financing crime typologies, national-level vulnerabilities and the coordination of the island’s National Risk Assessment, amongst other AML related matters.

There are a number of committees and other groups associated with AML/CFT work across the IoM government, and at the centre of this work is the Financial Crime Strategic Board which is chaired by the Chief Secretary. The meetings are well represented by all relevant government authorities with the Policy Office providing the secretariat functions; scheduling meetings, issuing agendas, circulating and producing papers and monitoring progress of action plans on behalf of the Board.

In addition, the Policy Office also participates in two additional AML/CFT specific groups:

• AML/CFT Advisory Group; a representative discussion forum for regulators, law enforcement authorities and industry, chaired by the Policy Office. This quarterly meeting provides a forum in which key stakeholders can discuss and comment on prospective changes to AML regulations and guidance. The aim of the AML/CFT Advisory Group is to strengthen communications and facilitate cooperation between government, regulators and industry in order to combat the misuse of the Isle of Man’s financial systems by persons attempting to commit financial crimes.

• AML/CFT Technical Group; a forum for coordination and discussion across Government as well as focussing on matters in respect of AML/CFT regulation and guidance and emerging issues in respect of the application of regulation. The overall purpose of the AML/CFT Technical Group is to provide advice and support to the Financial Crime Strategic Board in respect of the development of ML regulation, the implications for the Isle of Man regarding changes to international standards and the effectiveness of measures intended to tackle ML/TF at Government and industry level.

A significant amount of work has been undertaken since the publication of the island’s MER in 2016, including substantial investment in new resources for law enforcement and the Financial Intelligence Unit and the delivery of new AML/CFT related legislation. The AML/CFT Policy Office will continue on behalf of Isle of Man government to coordinate with the Financial Intelligence Unit, law enforcement and the island’s regulators in order to meet the challenge of tackling international financial crime and the funding of terrorism.

Financial Crime Strategic Board

The Financial Crime Strategic Board is Chaired by the Chief Secretary and comprises, ex officio, the acting HM Attorney General, the IoM Chief Constable, the Director of the Financial Intelligence Unit, the Chief Executives of both the IoM Financial Services Authority and Gambling Supervision Commission and a number of advisers from across Government.

The purpose of the Financial Crime Strategic Board is to provide an effective mechanism to enable Isle of Man Government, regulators and law enforcement authorities to coordinate the development and implementation of actions related to combating money laundering, terrorist financing, the financing of proliferation of weapons of mass destruction and other financial crimes.

In order to achieve this purpose, the Board is required to oversee the implementation of the Financial Crime Strategy and action plans arising out of the National Risk Assessment and international assessments such as the MONEVYAL Mutual Evaluation Report to ensure that identified risks are addressed and effective systems are in place.

It is the responsibility of the Financial Crime Strategic Board to set direction and establish working groups and sub-groups which will undertake work as directed by the Board, including policy and legislative development, informed by the risks identified and proportionate in their public impact.