On 23 October, MONEYVAL released a follow-up report which noted the continuing positive progress made by the Isle of Man to tackle money laundering and terrorist financing since the adoption of its mutual evaluation report in December 2016.  It notes the positive progress made by the FSA in the implementation of its sanctioning regime, and assigns the Island a higher international compliance rating in the area of tipping-off and confidentiality, and a positive compliance rating in the area of new technologies, including virtual assets.  It placed on hold the assessment for one rating related to group-wide requirements for non-financial businesses and professions, pending a decision on this issue by the FATF.  MONEYVAL says that the Island now has reached a level of full compliance with 20 of the 40 FATF Recommendations, but that  it retains minor deficiencies in the implementation of another 19 Recommendations, and larger-scale deficiencies for only Recommendation 23 (The requirements set out in Recommendations 18 to 21 apply to all DNFBP).  However, MONEYVAL decided that the Island will remain in the enhanced follow-up process and will continue to report back on further progress to strengthen its implementation of AML/CFT measures – reporting back next year.  The rating for Recommendation 15 has been downgraded due to the absence of wire transfer requirements for Convertible Virtual Currencies (CVC)/virtual asset service providers (VASP).

One should, of course, bear in mind that such follow-ups only deal with technical compliance, and not effectiveness of controls – the latter, measured by the Immediate Objective (IO) ratings, can only be reassessed following a full re-evaluation.

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at

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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