On 16th November, a news release from the Isle of Man FSA said that, in line with MONEYVAL’s common follow-up rules of procedure, the Isle of Man had to report back to MONEYVAL in July 2018 on the steps taken since the publication of the Mutual Evaluation Report in 2016 to strengthen its AML/CFT framework.  It says that this follow-up report (dated July 2018) has now been published and analyses progress in addressing the technical compliance deficiencies identified in the mutual evaluation report.  The report also looks at whether the Isle of Man has complied with the new requirements of those FATF Recommendations that have changed since 2016.  It quotes MONEYVAL as saying that: Overall, the Isle of Man has made commendable progress in addressing the TC deficiencies identified in its 5th Round MER and has been re-rated on 8 Recommendations (8 upgrades).  It notes that MONEYVAL re-rated the Isle of Man –

  • to “Compliant” with Recommendations 5 (criminalisation of the financing of terrorism), 6 (targeted financial sanctions on the financing of terrorism), 16 (wire transfers), 29 (FIU), 32 (cash couriers) and 33 (statistics); and
  • to “Largely Compliant” with Recommendations 24 (transparency of legal persons) and 35 (sanctions).

As a result, it says, the Isle of Man is assessed as Compliant or Largely Compliant on 38 out of 40 of the FATF Recommendations.  Note that these refer to technical compliance, whereas the “Immediate Outcomes” markings deal with the effectiveness of the compliance and controls.

The revised Technical Compliance markings are now –


The Isle of Man will remain in enhanced follow-up and will continue to report back to MONEYVAL on progress to strengthen its implementation of AML/CFT measures; and is expected to report back to the MONEYVAL Plenary within 1 year.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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