This section contains information and guidance to assist Regulated businesses in mitigating the risk from bribery and corruption. It also provides links to other organisations that may also be useful sources of information.
Regulated businesses should ensure that they are compliant with The Financial Services Authority AML / CFT Handbook which provides details for all licenceholders and registered persons to understand their obligations under the AML / CFT Code 2019. The preventative measures undertaken by licenceholders / registered persons must be applied on a risk based approach in order to avert or prevent financial crime from being facilitated within their entity as well as within our jurisdiction.
Specific reference to bribery and corruption or related activities is made by the Authority in:
- The FSA Rule Book 2016 – in Sections 6.9 (Gifts and Other Benefits) and 6.11 (Conflict of Interest)
- The Financial Services Authority AML / CFT Handbook - Section 3.8.3 (Politically Exposed Persons)
- The AML / CFT Code 2019 - Section 14 (Politically Exposed Persons)
The Financial Services Authority AML / CFT Requirements and Guidance provides sector guidance documents and red flags covering all aspects of financial crime. The Guidance also provides risk assessment templates and help.
Regulated business should also ensure that they stay up to date with the current Anti-Corruption Sanctions Guidance from the Customs and Excise Division.
The Gambling Sector
Licensees in the gambling sector in the Isle of Man are regulated entities. This means that they must adhere to obligations placed upon them by law to combat money laundering and terrorist financing. Collectively these requirements are known as AML/CFT controls (anti-money laundering/countering the financing of terrorism). The Isle of Man Gambling Supervision Commission is the regulator that supervises the Isle of Man gambling sector’s compliance with AML/CFT.
Gambling Supervision Commission AML / CFT Guidance
Reporting suspected Bribery and Corruption
Information for MLROs:
MLROs should report via Themis in the usual way.
Information for other staff:
If Bribery or Corruption are suspected within your organisation, they should be reported. In the first instance, you should inform your MLRO and follow your organisation's policy or pathway for reporting concerns.
If you do not feel that it is safe or appropriate to do so, you can report your concerns in confidence via the Reporting Form link on this page.
- You can also report your suspicions to the Isle of Man Constabulary or Crimestoppers.
- The Financial Intelligence Unit can receive any intelligence that assists it in the performance of its general functions.
Suspected Money Laundering linked to Bribery and Corruption
You should approach your Money Laundering Reporting Officer in the usual way, if you suspect money laundering linked to Bribery and Corruption.
If you do not feel that it is safe or appropriate to report your suspicions to your MLRO, you can also report your concerns in confidence via the reporting form link on this page.
Where can I get advice and guidance about my employment rights?
If you have any questions in relation to whistleblowing and your employment rights, the Manx Industrial Relations Service can provide guidance and advice.
The Department for Enterprise also publishes a Guide to Employment Rights. This provides a detailed overview of Isle of Man employment law and some other relevant legislation as at March 2022.