Our Island Plan

Sanctions relating to Terrorism and Terrorist Financing

In the Island, there are a number of sanctions regimes that relate to terrorism and terrorist financing.

For information on the sanctions regimes relating to terrorism and terrorist financing and the potential risks to businesses in the Island and how to mitigate those risks, please read the following guidance:

About terrorism and terrorist financing sanctions

What is terrorism and terrorist financing

In general terms, the financing of terrorism is the act of providing funds to terrorists or terrorist organisations in order for them to carry out terrorist acts or to benefit them. Terrorism or terrorist activities can include:

(a) Being responsible for, engaging in, or providing support for, the commission, preparation or instigation of acts of terrorism

(b) Providing financial services, or making available funds or economic resources, for the purposes of terrorism

(c) Facilitating, promoting or encouraging terrorism

(d) Providing or receiving training for the purposes of terrorism

(e) Travelling or attempting to travel from or into the relevant territory for the purposes of terrorism

(f) Carrying out recruitment activities for a person who is involved in terrorism

(g) Being involved in the sale, supply or transfer of arms or material related to arms to a person who is involved in terrorism

(h) Engaging in trade of whatever description with a person who is involved in terrorism

(i) Being responsible for, engaging in, being complicit in, providing support for, or promoting, the abduction, enslavement, forced marriage or rape of, or sexual violence against, persons outside the relevant territory on behalf of, or in the name of, a person who is involved in terrorism

(j) Supporting or assisting any person who is known or believed by the person concerned to be involved in any activity as mentioned in paragraphs (a) to (i)

(k) Being involved in assisting the contravention or circumvention of any relevant provision

Terrorist financing differs from money laundering in that the source of funds can either be legitimate, such as an individual's salary, profit from legal businesses or gifts including those made through non-profit organisations.

Similar to money laundering, terrorism financing often involves three steps: raising, moving, and using funds. Despite the various steps, financing terrorism is done in a manner similar to, and in some instances may be identical to, that of money laundering. In each instance, the offender aims to use the financial or non-financial sectors for improper ends.

The below PDF provides further information about terrorist financing.

Legislation

The United Nations sanctions regimes relating to terrorism and terrorist financing that have effect in the Island are stated below.

Although the Isle of Man is not a UN member in its own right, the UK’s membership of the UN extends to the Island.

Afghanistan

United Nations Security Council Resolution 1988 (2011) which is legally given effect in the Island by:

a) Sections 44-50 of the Terrorism and Other Crime (Financial Restrictions) Act 2014 and

b) The Afghanistan (Sanctions) (EU Exit) Regulations 2020 which have effect in the Island by the Sanctions (Implementation of UK Sanctions) Regulations 2024

Impose the following types of sanctions:

  • Targeted asset freeze
  • Trade sanctions

ISIL and Al-Qaida

United Nations Security Council Resolution 1267 (1999) which is legally given effect in the Island by:

a) Sections 44-50 of the Terrorism and Other Crime (Financial Restrictions) Act 2014 and

b) The ISIL (Da'esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019 which have effect in the Island by the Sanctions (Implementation of UK Sanctions) Regulations 2024

Impose the following types of sanctions:

  • Targeted asset freeze
  • Trade sanctions

United Kingdom sanctions regimes

The United Kingdom sanctions regimes relating to terrorism and terrorist financing that have effect in the Island are counter-terrorism designations implemented pursuant to United Nations Security Council Resolution 1373 (2001) which is legally given effect in the Island by:

a) The Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 which have effect in the Island by the Sanctions (Implementation of UK Sanctions) Regulations 2024

b) The Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019 which have effect in the Island by the Sanctions (Implementation of UK Sanctions) Regulations 2024

Impose the following types of sanctions:

  • Targeted asset freeze
  • Trade sanctions
  • Immigration

Isle of Man sanctions regimes

The Treasury also has the power to designate persons pursuant to United Nations Security Council Resolution 1373 (2001).

Designations may be made under section 18 of the Terrorism and Other Crime (Financial Restrictions) Act 2014

Impose the following types of sanctions:

  • Targeted asset freeze

There are currently no designations made under this power. Further information can be found on the Sanctions Lists page.

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What do I need to do

If, through your sanctions compliance programme, you identify a possible match to a person or entity included in a Sanctions List:

  1. You must immediately freeze any assets you hold or otherwise deal with belonging to that person (assets includes funds and economic resources, owned directly or indirectly by that person

  2. You must review the information you hold for that person against the UK Sanctions List to establish whether you have a true match or a false positive (information can be found in the Financial Sanctions General Guidance)

  3. Where a true match is confirmed, do not deal with those assets or make them available to, or for the benefit of the designated person unless:
    • You have a legal exemption
    • You have a licence

  4. You must report the frozen assets to the FIU

If you have a suspicion or knowledge that there has been a breach of sanctions law, or any attempted transactions that you have blocked, report your suspicions to the FIU.

If you are a relevant firm, you must have appropriate AML/CFT/CPF policies, procedures and controls in place to mitigate the risk of breaching sanctions law.

You must have appropriate procedures in place to be able to:

Note: determining if a customer is on a Sanctions List includes whether any corporate entity is owned or controlled, directly or indirectly, by a person on a Sanctions List.

You should also ensure that you and your employees have appropriate training and keep this up to date. Further guidance on sanctions compliance can be found below:

Further guidance on false positives and delistings and what to do can be found in the Financial Sanctions General Guidance:

Reporting requirements

The financial sanctions regimes have two reporting components to them. The first is a general obligation that applies to everyone. The second is a more targeted obligation that applies to specified businesses and professions. Further information on reporting requirements and how to make a report can be found on the Reporting page:

Proposals and challenging designations

The Treasury has the power to designate persons pursuant to United Nations Security Council Resolution 1373 (2001).

Anyone can propose a sanctions designation to the Treasury. This includes:

  • Government authorities (domestic or international)
  • Businesses (including those in the regulated sector)
  • Charities and NGOs
  • Individuals with relevant information

Information on how to make a proposal or challenge a designation can be found on the below page.

Further Information and Guidance

Further information on the sanctions regimes relating to terrorism and terrorist financing can be found in the following guidance.

For information highlighting potential risks to businesses in the Island from terrorism and terrorist financing and how to mitigate those risks, please read the following guidance:

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