Under the Isle of Man’s anti-terrorism and sanctions legislation it is illegal to make payments to terrorists and terrorist organisations or for the purposes of terrorism, either directly or indirectly.
In particular, such payments made to any individuals, undertakings or entities included on the Al-Qaida Sanctions List for the purpose of ransoms would be illegal, regardless of how or by whom the ransom is paid.
The prohibitions have extra-territorial effect, meaning that an offence can be committed by Island persons or legal entities, even if the activity takes place outside the Island.
However, a clear distinction may be made between payments of ransom to terrorists, or for the purpose of terrorism, and those which may be made for reasons of other forms of criminality, such as piracy at sea.
Businesses and individuals are advised to exercise extreme caution in respect of any transactions that involve the payment of ransoms. Any relevant information should be reported to the Isle of Man Treasury’s Customs and Excise Division if potential sanctions issues are involved, or to the Financial Crime Unit.
Any request to become involved in a transaction involving the payment of a ransom may give rise to knowledge, suspicion or reasonable grounds for knowledge or suspicion of another’s involvement in criminal activity or terrorist financing, in which case consideration should be given to whether a disclosure should be made to the Financial Crime Unit or to the appropriate authorities in the destination of any funds involved.