AML/CFT Policy Office

The AML/CFT Policy Office was established by the Chief Secretary in 2016. The Policy Office acts as the coordinating body for the Isle of Man’s Anti-Money Laundering and the Combatting the Financing of Terrorism (AML/CFT) regime, coordinating the Island’s 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 coordinated 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 Man’s AML/CFT measures. The findings of that assessment were published in the Fifth Round Mutual Evaluation Report of the Isle of Man (MER).

The Policy Office is responsible for monitoring progress against both the MER recommendations and evolving international AML/CFT standards, reporting to MONEYVAL on a regular basis. In addition to acting as the main conduit between the Isle of Man Government and the relevant international bodies, the Policy Office also leads the AML/CFT National Risk Assessment process and the development and coordination of national Financial Crime Strategies, reporting on progress to the Financial Crime Strategic Board.

In 2023 the Isle of Man Government published the Financial Crime Strategy 2024 – 2026, the Island’s fourth national strategy specific to fighting financial crime. The Strategy adopts 8 Strategic Objectives, each comprising a number of Strategic Actions and Measures of Success. The Strategic Objectives are:

1. Continue to meet the highest international standards, adapting or updating our approach in line with changes or developments
   
   
2. Use a risk-based approach to identify risk, coordinate appropriate actions and apply resources to ensure identified risk is addressed and mitigated
   
   
3. Pro-actively share and seek knowledge and expertise to ensure our response is underpinned by best practice
   
   
4. Ensure that our supervisory authorities are empowered and appropriately resourced to inspect, detect, investigate and where appropriate sanction instances of non-compliance with ML/TF/PF preventative measures
   
   
5. Ensure that our law enforcement and justice systems are empowered to detect, investigate and where appropriate prosecute ML/TF/PF, appropriately sentence offenders and to confiscate or forfeit illegally obtained assets
   
   
6. Fully understand the immediate, emerging and ongoing threats posed by financial crime using a broad spectrum of metrics, data and statistics, and conducting strategic analysis
   
   
7. Remain vigilant and responsive to the threats to the Island arising from terrorist financing and financing the proliferation of weapons of mass destruction
   
   
8. Embed a cycle of continuous improvement across the Isle of Man in our work to address financial crime

A National Action Plan sets out how these Strategic Objectives will be met, to ensure the Mission Statement of delivering an all-Island approach to tackling financial crime is achieved.

Anti-Bribery and Corruption Project

Isle of Man Government - AML/CFT Committees

The Financial Crime Strategic Board

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. The Board is made up of senior officers from law enforcement, regulatory authorities, the Attorney General’s Chambers and the Financial Intelligence Unit.

The Policy Office provides the secretariat functions for this committee, scheduling meetings, issuing agendas, circulating and producing papers and monitoring progress of action plans on behalf of the Board.

The AML/CFT Advisory Group

The Advisory Group is a representative discussion forum for professional and industry bodies to meet with Government agencies, including regulators and law enforcement authorities and industry. It is organised by the Policy Office and meets on a quarterly basis. The 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 threats to the Isle of Man’s financial systems by persons attempting to commit financial crimes.

The AML/CFT Technical Group

This Group is a cross-Government forum for discussion and coordination of AML/CFT and proliferation financing matters. It focuses on matters in respect of regulation and guidance and emerging issues in respect of the application of regulation. The Technical Group provides advice and support to the Financial Crime Strategic Board in respect of the development of ML/TF 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.