The Role of the Financial Intelligence Unit in the Isle of Man Presented By Kirsty Knight
Who are We?
What do we do? Act as the Island’s national centre for the receipt and analysis of SARs Proactively develop intelligence packages and disseminate them to Law Enforcement, regulatory and other partner agencies both in the Isle of Man and Overseas Identify and promote the legislative and policy changes required to ensure that the Island’s laws prevent it from being used for national and cross border financial crime and terrorism financing
What do we do? Work with the Island’s regulators and Government departments, the Island’s financial services industry and relevant non-financial sectors, to increase awareness and compliance with anti-money laundering procedures and procedures to combat terrorist financing Represent the Island at international money laundering and terrorism forums such as Egmont Ensure that all activity undertaken meets the FATF/Egmont standards
What information do we receive? Information received by the FIU is pre-dominantly received on an online reporting system – Themis The information received is by way of a SAR (Suspicious Activity Report), other Law Enforcement Agencies and Financial Intelligence Units The SAR is then allocated for review by one of the Intelligence Officers and it is decided whether any further action/dissemination is required We can also receive matters for consent and we have the option to ‘Consent’ or ‘No Consent’ . A decision must be made within 7 days of receipt then the business has ‘deemed consent’ If a ‘No Consent’ is given there is a 31 day period whereby an investigation can be taken up and assets seized
Who Do We Share With? The FIU has worked closely with multiple Government Departments and Statutory Boards including:- – DED – Customs – Income Tax – Social Security – Isle of Man Constabulary – GSC – FSA
SARs By Sector Sector April May June July August September Accountant 1 4 0 3 2 1 Bank/Building 56 65 75 65 78 62 Financial 1 0 1 1 2 2 Advisors Investment/ 2 1 0 3 1 1 Fund Manager Lawyer 4 0 9 1 1 2 Life Assurance/ 18 4 12 10 8 11 Insurance Money Service 3 3 0 2 3 4 Online/eGame 5 22 16 24 12 33 Other 0 0 0 1 0 0 Post Office 0 0 0 0 1 2 TCSPs 16 9 11 9 11 7 TOTAL
FIU Progress The FIU has delivered presentations and training to 5 banks, 3 Government Departments, 2 professional bodies and one local tax firm to increase local knowledge of the functions of the FIU Cash restrained as a result of 17 cases generated by the FIU to date is £41,752,359 The Financial Crime Unit alone has received 34 intelligence packages to consider for investigation since April 2017 Focus on risk sectors – Estate Agents – Charities
Good & Bad SARs Good – If adverse media related the article is attached – Own research is conducted – To the point Bad – Lacking in detail (especially if consent is requested) – Details of transaction/destination not provided – Suspicion not clear
The FIU Act The Financial Intelligence Unit has its own legislation which came into force in April 2016. The main parts used by the Unit are:- – Section 18 – The power to gather additional information – Section 24 – Disclosure of information to FIU – Section 23 – Disclosure of information by FIU – Section 25 – Restrictions on further disclosure – Section 30 - General duty to pass information – Section 31 – General duty to assist the FIU
Other Relevant Legislation – Section 145 – Tipping Off (POCA 2008) – Beneficial Ownership – 1 July 2017 – Sanctions – Bribery
Progress & Improvements Feedback Human & Other Resources Develop & implement intensive training – NCA - Financial Intelligence Officer – SO15 Terrorist Financing Training – Egmont – Strategic Analysis – Egmont- Operational Analysis – ICA Diploma in AML – 1 newly qualified, 3 commenced
Coming Up… SAR Guidance & Training TF Guidance & Training Typologies Publishing Sanctions Reporting
Any Questions Any further queries please contact kirsty.knight@gov.im or call 686011
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