FSA publishes findings of sanctions thematic

In early 2024, the Isle of Man Financial Services Authority (the Authority) issued  a sanctions-themed questionnaire to all registered and regulated firms across the Isle of Man. The questionnaire focused on assessing firms’ procedures and controls related to sanctions, as well as their adherence to the Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Code 2019. In December 2024, the Authority published their findings from the questionnaire.

The questionnaire served to gather and analyse data to enhance the Authority’s evidential understanding of potential risks and will be used to make informed updates to the Island’s National Risk Assessment. An impressive response rate of 98.5% was achieved, with 596 firms participating.

The Phase One questionnaire concentrated on several key areas: sanctions screening, ongoing monitoring, staff training, and procedures and controls. This phase aimed to assess how well firms are implementing and managing their sanctions-related obligations.

Building on the findings from Phase One, the Authority will now begin Phase Two, which involves testing the procedures and controls of selected firms. Phase Two includes on-site inspections, initially targeting Class 1 (Deposit Taking) licenceholders.

Key Takeaways

  • Maintain up-to-date and commensurate procedures that are appropriate for the business to mitigate any risks associated with sanctions.
  • Firms must screen customers against sanctions lists to ensure compliance with the Code.
  • Regularly review the sanctions control environment to ensure its effectiveness.
  • Report any suspicious activity or sanctions hits to the relevant authority.

 

Where can I find out more?

For further guidance on the Code requirements regarding sanctions, we encourage firms to explore our e-learning module to ensure their own compliance regimes are effective, up-to-date and properly documented.

For more information on our e-Learning platform click here.

 

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