On 13 January, the Isle of Man advised of the publication of an updated NRA, which is a requirement of FATF.  As with the original NRA, it was carried out with cross-government participation and input from the private sector, but also builds upon the 2015 assessment and the findings and recommendations of the MONEYVAL Mutual Evaluation Report of 2016.  The NRA confirms the overall level of risk for the Island are that the money laundering risk remains “Medium-High” and the terrorism financing risk as “Medium-Low”.  Amongst the points mentioned is that –

  • the Customs and Excise Division of Treasury is engaging with OFSI in the UK new ‘Virtual Sanctions Network’ which has the aim of promoting dialogue and cooperation between the UK, the Crown Dependencies and the Overseas Territories;
  • reforms introduced by government, including increased investment, are taking effect. The reforms have been underpinned by strategy, policy and procedural development enabling the authorities to work together in a more collaborative and effective manner;
  • effective use needs to be made of new powers, procedures and resources that have been allocated to the authorities;
  • accuracy of the Beneficial Ownership database is tested by the FSA using a risk-based approach; however, the accuracy and completeness of identity and verification details on registration need to be reviewed;
  • the impact of the UK exit from the EU is currently unknown;
  • there has been a significant increase in casework for the Economic Crime Unit (ECU) from 34 cases in 2016/17 to 90 in 2018/19; the main predicate crimes for money laundering continue to be fraud, false accounting and deception. Two-thirds of the cases being investigated by the Economic Crime Unit arise from predicate offending outside the Island.

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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