The Isle of Man Financial Services Authority (IOMFSA) are increasingly conducting random regulatory reviews on IOM Designated Businesses including Estate Agents, Accountants, Law Firms and Payroll agencies.
As a result of the increased oversight by the Authority, inspections and thematic reviews are more likely. As we see them stepping up their enforcement role it is something every company should be prepared for.
Being unprepared for Authority inspections can be costly in terms of:
- the financial penalties that may be imposed
- the damage to a company’s reputation
- the time it takes to prepare the requested deliverables
- the mental stress created for all involved if a company is not prepared
Therefore, it’s essential to be prepared.
What kind of visit can you expect to receive?
Currently we are seeing the IOMFSA carrying out visits around thematic reviews. Most recently we have seen businesses contacted around their processes and frameworks for:
- Sanctions
- Foreign PEPs
The Authority will request a series of deliverables which may include:
- Business Risk Assessment
- Policies and procedures
- Registers
- Staff training records and material
- Assurance reports on the testing of monitoring of thematic topic
- Details of any Board/Senior Management reporting on the thematic topic.
Are you and your company ready for this?
What are the key things to be aware of around Sanctions and Foreign PEPs?
It is key as a designated business that you have comprehensive and robust policies and procedures covering both Sanctions and Foreign PEPs.
These policies and procedures should be regularly tested and monitored, so when the IOMFSA come knocking you are in a good place.
For Sanctions this would include maintaining documentary records of screening activities including the rationale and treatment of false positives.
In terms of PEPs it is a code requirement to ensure that your client risk assessment factors in Domestic and Foreign PEPs and whether deemed standard or high risk.
We support our clients by testing and monitoring to establish whether a companies’ screening process is fit for purpose.
We look for the gaps so that our clients don’t have to.
What can you do to be prepared?
Have a clear understanding of the applicable regulations and ensure that all compliance procedures are up to date.
Additionally, it’s important to have a plan in place for responding to regulatory inquiries. By taking these steps, companies can minimise the risk of facing serious consequences as a result of a regulatory visit.
You don’t have to do all of this alone.
If you are responsible for AML and CFT in a small designated business in the Isle of Man, the chances are you wear a number of ‘hats’.
It’s extremely tricky for you to stay abreast of everything, and the stress of that may hang around like a bad smell.
But you’re not alone. We exist for small businesses like yours, and our assistance comes without the Blue Chip price tag.
When you have Impact on your team we have manual oversight of your processes and frameworks, and steer you and your company in the right direction.
We live and breathe compliance every day, and we love using this knowledge to support people who are too busy to get right into the detail.
We can review and test your process, and create an actionable road map to get you to where you need to be when the Authority comes knocking.
Have you downloaded our free guide to the AML/CFT Handbook revisions yet? Grab a copy today (and receive monthly industry news when you sign up).
