On 11 May, an article from the CSB Group advised that the Financial Intelligence Analysis Unit (FIAU) has published an Enforcement Factsheet, drawn up by its Enforcement Section and, in tandem with the preceding Business Risk Assessment, aims to assist those subject to regulations in enhancing the compliance to AML/CFT obligations.  The Enforcement Section has analysed the enforcement actions undertaken by the FIAU in 2019 and 2020 and the factsheet presents the conclusions of this analysis.  It is said that the most common finding noted across all sectors relates to the appreciation of risk, both at the institutional level and at the customer level.  Other common findings relate to the requirements to have in place comprehensive customer risk profiles, transaction monitoring procedures and the need to consider occasional transactions within the context of all that is known about the customer, including past activity.

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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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