Crest
Isle of Man Government
Reiltys Ellan Vannin
Isle of Man Government Crest

F.S.C. Handbooks

Search regulated entities

Anti Money Laundering Guidance Notes

Contents

A message from the Chief Executive

section 1

INTRODUCTION

1.1What is money laundering?
1.2What is terrorist financing?
1.3Areas of concern
1.4The consequences of 11 September 2001
1.5Know your customer and customer due diligence
section 2

ISLE OF MAN LEGISLATIVE AND REGULATORY FRAMEWORK

2.1Legislation
2.2The regulatory backdrop
2.3Requirements of the Criminal Justice (Money Laundering) Code 2007
2.4Businesses covered by the Code
2.5Criminal Justice Act 2001
2.6Sanctions Notices
2.7Group Anti-Money Laundering Policies
section 3

ESTABLISHING NEW BUSINESS RELATIONSHIPS AND IDENTITY

3.1Existing business relationships
3.2Direct personal clients
3.3Direct corporate clients
3.4Introduced business and agency/nominee instructions
3.5Trust clients
3.6One-off transactions and exempted one-off transactions
3.7New mailshot, coupon, off the page and telephone business
3.8Internet banking and investment business accounts
3.9 Bearer shares
3.10Provision of safe custody and safety deposit boxes
3.11Provision of safe custody and nominee facilities
3.12Managed licenceholders
3.13Correspondent banking relationships
3.14Non-profit organisations
3.15Source of funds and source of wealth
3.16Politically Exposed Persons (PEPs) and other high risk customers
section 4

ONGOING MONITORING OF BUSINESS RELATIONSHIPS

4.1Monitoring
4.2"Hold Mail" Relationships
4.3Pooled accounts / acting on behalf of another (including designated client accounts)
4.4FATF Special Recommendation VII ("SR VII")
4.5Alternative remittance systems
section 5

CONTROLS AND COMMUNICATION

5.1Appointing a Money Laundering Reporting Officer (MLRO)
5.2Identifying the MLRO and reporting chains
5.3The scope of the role of the MLRO
5.4Recording disclosures
5.5Data Protection Act 2002
section 6

REPORTING SUSPICIONS

6.1Identifying suspicions
6.2Cash transactions
6.3Questions to ask yourself
6.4Reporting suspicions
6.5The timing of disclosures
6.6Unreasonable customer instructions
6.7Reporting declined business
6.8Back office functions
section 7

RECORD KEEPING

7.1Records
7.2Contents of transaction records
7.3Establishment of registers
7.4Reliance on third parties
7.5Responding to production orders
section 8

TRAINING, AWARENESS AND STAFF SCREENING

8.1Isle of Man Constabulary Training
8.2The timing and content of training programmes
8.3Staff awareness
8.4New employees
8.5Operations staff
8.6Training for supervisors and managers, and person acting as directors or secretaries of client companies
8.7Training for Money Laundering Reporting Officers
8.8Continuing vigilance and refresher training
8.9Staff Screening
section 9

CULTURE

9.1Compliance culture and the compliance function
9.2Vigilance
9.3Robustness
section 10

Appendices

Appendix A Background Information on money laundering
Appendix B(a) Criminal Justice (Money Laundering) Code 2007
Appendix B(b)Criminal Justice (Money Laundering) (Amendment) Code 2007
Appendix B(c) Criminal Justice (Money Laundering) (Amendment) Code 2008
Appendix CRequest for verification of customer identity
Appendix D FATF Member Countries and equivalent territories
Appendix E(a)FATF 40 Recommendations and Interpretative Notes
Appendix E(b)FATF Special Recommendations on Terrorist Financing
Appendix F(a)Eligible Introducers
Appendix F(b)Eligible Introducer's Certificate
Appendix GExamples of suspicious transactions
Appendix HSpecimen Isle of Man Disclosure Form
Appendix JFurther guidance from the Isle of Man Constabulary FCU
Appendix KCurrent legal issues
Appendix L (a) Anti-Money Laundering Flowchart
Appendix L (b) Introduced Business
Appendix M(a)Acceptable Applicants
Appendix M (b)Acceptable Applicant's Certificate
Appendix N Other legislation including offences and defences

NB Where the masculine gender is used it also implies the feminine.

Download BrowseAloudTerms & Conditions©2008 Isle of Man Government