On Jan. 2, 2025, IOM FSA confirmed it launched the AML/CFT annual statistical return for 2024, due to be completed by all regulated and registered firms by Mar. 31, 2025.
IOM FSA implemented improvements to AML/CFT annual statistical return for 2024, and work taking place to update National Risk Assessment (NRA),including timeline.
Planning improvements to AML/CFT Annual Statistical Return (the return) for the year 2024, which will be issued in Jan. 2025 with a view to complete by Mar. 31, 2025.
IOM FSA's AML/CFT Supervision Division (division) has been reviewing data from the 2023 return and looking at outcomes from the first year of utilizing STRIX.
Division has also reviewed feedback from industry and work is underway to improve the 2024 return, including rephrasing and simplifying questions where appropriate.
Also, strengthening the accompanying guidance, removing and adding questions as needed with the aim of enhancing the user's overall experience of the return.
The new deadline for the return as at Dec. 31 will be Mar. 31 of each year.
Updated return guidance, has list of questions available to firms in early Dec. 2024.
Connection to National Risk Assessment
Along with other regulators and jurisdictions globally, IOM FSA wishes to be aligned to international standards and aims to work with the most accurate and up-to-date data.
In terms of data available to inform the risk-based approach and allow for more efficient decision-making, and this data is also instrumental on other work too.
Including, 3rd National Risk Assessment to support the risk-based engagement planning which takes place in Apr. annually, and IOM FSA needs most recent data.
Work includes collating and analyzing information already held, and gather the additional data and feedback required in order to identify threats to the Island.
Such as money laundering (ML), terrorist financing (TF), proliferation financing (PF).
NRA is scheduled for publication in early 2025, and is key to protecting the Island from financial crime and is a crucial element of meeting international standards.
Assessment of NRA looks in detail at existing and emerging risks as per Island's financial and specified non-financial sectors, and the measures to mitigate those risks.
IOM FSA findings will inform policy and focus resources where they are most needed.
Timeline of NRA key milestones have been set out by IOM FSA on their webpage.
Dec. 6, 2024 Further Information
On Dec. 6, 2024, IOM FSA issued updated AML/CFT annual statistical return guidance, with more on 2024 return changes: to be issued Jan. 2, 2025, deadline Mar. 31, 2025.
Is assessing stakeholder feedback, so guidance may be subject to further changes.
80 questions removed, 27 new conditional questions; 35 new risk and control data questions; 16 conditional questions added to the risk sections to hide 46 questions.
Plus new risk sections/questions on: incidental business; unique ultimate beneficial owner jurisdictions; IOM incorporated firms; products and services; use of simplified customer due diligence; 11 conditional control section questions/hiding 73 questions.
New control sections including questions on; procedures, controls and BRA; staff training; sanctions reporting; STRIX can be accessed at https://fsareturns.im/.
Jan. 2, 2025 Statistical Return Live
On Jan. 2, 2025, IOM FSA confirmed it launched the AML/CFT annual statistical return for 2024, due to be completed by all regulated and registered firms by Mar. 31, 2025.
