The Isle of Man Financial Services Authority has made some amendments to its 'Anti-Money Laundering and Countering the Financing of Terrorism Handbook,' adding a section regarding the assessment of risks associated with introducers and some guidelines about meetings with customers.

Throughout the rulebook, references to the Insurance and Pensions Authority, the financial intelligence unit, the Economic Crime Unit and the old Financial Services Commission have been updated. References to ‘face to face’ have been amended to ‘met.’ Section 1.2 has been updated with reference to s157 Proceeds of Crime Act 2008. Section 1.5 has been updated to take account of the fact that jurisdictions are assessed against the FATF requirements. Section 1.6 has been updated to say that breaches of the sanctions list should be reported to the FIU. Section 2.1 has been updated to account for the fact that procedures are required for sanctions screening and wording has been added regarding the fact that responsibility for compliance with the Anti-Money Laundering and Countering the Financing of Terrorism (Amendment) Code 2018 always remains with the relevant person. Section 3.1.2 has been updated to ask whether a relevant person usually meets customers and whether the requirements of paragraph 15(5) of the code need to be considered in the Business Risk Assessment.

Section 3.3 has been updated to accommodate the requirements of paragraph 10A of the code, and says that the requirements of paragraph 15(5) of the code must be considered in the Customer Risk Assessment. Section 3.3A has been added to deal with the new requirements of paragraph 10A of the code. Section 3.3.5 has been updated to differentiate between introduced business and use of the Eligible Introducer concession. Section 3.3.6 has been updated to deal with meeting the customer. Section 3.4.1 has been updated with wording regarding scrutiny of sanctions lists. Section 3.4.2 has been updated with wording regarding sanctions lists, the location of the customer or business activity and whether the customer has now been met. Section 4.3.4 has been updated with wording regarding the identification of the person who has control of a relationship. Section 4.4.1 has been updated with wording regarding the fact that paragraph 11 of the code applies when new requirements have been added to the code. The concessions table in section 6.1 has been updated. Section 6.2 has been updated to remove references to non-eligible introducers throughout. Section 6.2.2 has been updated with wording regarding taking steps to ensure that the customer is acting on his own behalf, identifying the sources of funds, the requirements of paragraph 5A of the code and the need to consider the suitability of 'customer due diligence' (know-your-customer controls) being undertaken by the Eligible Introducer. Section 6.2.3 has been updated with wording regarding what must be done if the conditions of the concession are not observed. The entirety of section 6.4 has been updated to accommodate the changes in the code regarding the "acting on behalf of" concession. Section 7.3.5 has been updated with wording from Customs and Excise and the glossary has been updated. Various appendices have been updated also.

It is the regulator’s expectation that the new procedures required by the Anti-Money Laundering and Countering the Financing of Terrorism (Amendment) Code 2018 will be in place by the end of May next year. The risk assessments of introducers required by that code should be carried out for any new business immediately, and for existing business at their next scheduled review.

The regulator's AML team is working on an update to the code itself, with yet another update to the rulebook to follow.