
In October next year MONEYVAL, the Council of Europe’s anti-money laundering watchdog, will be carrying out an onsite evaluation to assess whether the Isle of Man’s legislation, policies and procedures continue to meet international standards. Private sector support is vital if the Island is to match the evaluations achieved already by Jersey and Guernsey. This means that there is now a renewed focus on anti-money laundering (AML) training for businesses which includes input about MONEYVAL. In this article Rob Kinrade, Chief Executive of AML training experts, Expol, looks at the key issues for business owners and managers to consider.
MONEYVAL evaluations are always important to ensure the Isle of Man retains its reputation as a robust, well-regulated, international business centre. But several factors make next year’s assessment even more significant.
The Isle of Man’s last MONEYVAL evaluation was in 2016, with enhanced follow up in 2018. European and international standards regarding AML and CFT (Countering the Financing of Terrorism) have changed significantly since then, so the MONEYVAL evaluation next year will be the first time assessors have looked in minute detail at how the Isle of Man’s regulations and procedures have evolved to keep pace.
Crown Dependencies context
Within the past year MONEYVAL has reported its evaluations of Jersey and Guernsey with the assessments for both Crown Dependencies, on the whole, being positive. This puts a little more pressure on the Isle of Man to achieve an assessment that’s on a par with or better than these competitor jurisdictions. Pressure has been increased further by the Isle of Man’s image as a leading international business centre being tarnished to a degree in the past 12 months by negative headlines about businesses failing to follow best practice regarding anti-money laundering protocols. MONEYVAL evaluators have the power to ‘grey list’ jurisdictions and such outcomes can have a serious and long-term economic impact, so there is no room for complacency.
On the positive side, the Isle of Man Government is taking the lead to ensure that the public and private sector – plus the wider community – understand the importance of MONEYVAL for businesses and the economy. In July this year, the government published its first standalone Terrorist Financing National Risk Assessment which was a significant step forward in strengthening the Island’s level of protection against terrorist financing. It’s also relevant to MONEYVAL because it’s an important element in the strategy to meet Financial Action Task Force (FATF) recommendations. It’s also worth noting that two FATF members are designated by the FATF President to be members of MONEYVAL for a two-year period. In February last year Jane Poole-Wilson MHK, Deputy Chief Minister and AML/CFT lead for the Isle of Man Government, made it clear that the government needs private sector collaboration and support. Isle of Man Government, she said, is keen to ‘ensure effective collaboration between industry, the government and the financial services regulator’ with the aim of ‘driving a robust and co-ordinated national response which will demonstrate the integrity of the Island’s financial systems and maintain our long-standing track record of compliance with international standards’.
What are businesses doing?
There are many things that businesses are, or should, be doing to provide support, the most important being to ensure their processes, procedures and people are up to speed with the highest standards of AML and CFT knowledge and training.
While many firms invest in AML training – especially for Money Laundering Reporting Officers (MLROs) – in the countdown to the MONEYVAL evaluation some are choosing to go a step further with advanced levels of training. This typically involves the following:
- A law refresher course focusing on relevant legislation and case law
- Best practice regarding identifying and managing risks
- Explaining how MLROs should liaise with law enforcement agencies, including the Financial Action Task Force (FATF) which is the global anti-money laundering and anti-terrorist financing watching.
- Everything that needs to be done immediately, and regarding ongoing checks, to ensure continued AML and FATF compliance
This high level of continual training and professional development is becoming increasingly important because the regulatory landscape is constantly evolving. One recent example is a warning to companies issued by the Isle of Man’s Gambling Supervision Commission (GSC) about engaging with clients in some countries regarded as being a significant risk. Since then Expol has been very busy with enquiries from local CSPs, gaming companies and other related businesses wanting to carry out enhanced due diligence on existing clients from those countries.
Summing up
Everyone who has an interest in the Isle of Man’s future prosperity as an international business centre – especially for financial services and gaming – has a duty to play a part in helping to ensure the Island achieves a positive MONEYVAL evaluation. Our local knowledge tells us that while many businesses here on the Island have preparations well under way, others are playing catch-up. In this context, sharing knowledge and best practice across the public and private sectors will be a great asset in the months ahead.




