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Update from the Director

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02/04/2020

The IOM Financial Intelligence Unit (FIU) continues to function as normal and the majority of the FIU staff are working remotely. We may experience some minor delays to our “business as usual” and the unpredictable nature of the current situation may result in an increased demand. Please do not call into the FIU in person for obvious reasons.

Suspicious Activity Reports (SAR’s) submitted via the online portal THEMIS will continue to be actioned as normal. It would be very helpful if you can advise the FIU if you are experiencing any issues that may cause delay or prevent you submitting SAR’s in a timely manner. If you are experiencing any issues with regards to THEMIS or the submitting of SAR’s could you please initially contact the office on fiu@gov.im.

We recognise that the demand on your business will continue. The FIU anticipates that the circumstances of the COVID-19 pandemic will lead to an increase in financial crime and money laundering. Criminals may try to take advantage of the current situation, people and businesses in trouble may conduct criminal activity in an attempt to compensate financial losses. The IOM FIU is ready to respond and deal with financial crime and together with our counterpart agencies will be aiming to detect, prevent and reduce financial crime.

We believe that the MLRO function has an increased importance at this time. Your already important role will be enhanced and we believe that a higher level of vigilance is necessary to combat and prevent financial crime and the laundering of illicit funds. We appreciate that the majority of you will be working from home and this may affect your capabilities, and whilst we don’t need to know your specific circumstances we would appreciate information if you are not able to perform your role effectively.

In an attempt to support businesses with their duties the FIU are conducting a risk assessment on “the impact of COVID-19 in respect of financial crime on the Isle of Man both domestically and internationally”. This risk assessment aims to identify specific risks and identify mitigation strategies to reduce the likelihood and impact of financial crime within the Isle of Man and to protect the good reputation of the Isle of Man as an International Financial Centre. We aim to publish this assessment imminently.

Thank you for cooperation and support and please stay safe.

Phil Hunkin

FIU Director