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Sanctions and TBML Typologies - Feb 2023

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Check out the latest FIU Typology - Sanctions and Trade Based Money Laundering - Full document here.


Sanctions are prohibitions and restrictions put in place with the aim of maintaining or restoring international peace and security. They generally target specific individuals or entities, or particular sectors, industries or interests. They may be aimed at such people and things in a particular country or territory, or some organisation or element within them.
There are also sanctions that target people and organisations involved in terrorism.
As of 3rd April 2018 the FIU became the IOM body to whom suspicions of breaches of financial sanctions should be reported; this role was previously undertaken by Customs & Excise. The FIU also receives reports where an organisation has frozen an account where they suspect a breach of financial sanctions.
Once the decision was taken by the UK to leave the EU, the UK enacted the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act), and UK sanctions regimes are now in force under that act. This legislation has enabled the UK to transition existing EU regimes into UK law and establish UK autonomous regimes. The Foreign, Commonwealth and Development Office (FCDO) updated the UK Sanctions List at 11pm on 31st December 2020 and from that point, it became the definitive list of all UK sanctions imposed under the Sanctions Act.
From 1st January 2021, EU sanctions no longer applied in the IOM. The UK sanctions regime took precedent and has been applied in IOM law. From that date, it became the policy of the IOM Government to maintain the implementation of international sanctions measures in the Isle of Man, in line with such measures as have effect in the United Kingdom.