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Banking matters continue to have a significant
place on our agenda with ongoing reform
discussions with local banks relating to both
local policy implementation and responding
to the wider global requirements. At the
same time, we are aware of some of the
challenges being faced in the banking
environment with ongoing consolidation in
that industry and its impact on the local
economy. We are contributing to broader
discussions on this trend both here and with
our counterparts in other jurisdictions, and
this remains a difficult trend to arrest. The
introduction of the Alternative Banking
Regime this past year is intended to provide
additional diversity in banking choices and
over this period we have met with many
parties interested in pursuing this class of
licence. During the year we have issued some
additional guidance to inform this interest
and we remain confident that material
progress will occur over the next year.
The Designated Businesses registration
process completed this year with more
registrants than we expected; some 316
businesses are now registered. We are now
commencing our on-site phase of the
programme and have revised our visit
schedule to accommodate the increased
number of registrants. The upfront work of
the Authority during the lead-up to the
registration has renewed awareness of the
AML obligations of the Designated
Businesses community and this will
hopefully result in positive outcomes during
the on-site phase.
A significant work effort was undertaken by
the Authority related to the MONEYVAL
review undertaken last summer.
While many positive ratings in relation to the
activities of the Authority were achieved, it
was observed that there are areas for
improvement. Earlier this year we held an
industry forum to share the major findings
and to mobilise industry working groups to
collectively agree a way forward. This will
continue to be an area of significant work
for the Authority in the coming year and
will necessitate ongoing collaboration
with industry and other government
departments alike.
Over this past year some of the activities of
the Authority have garnered enhanced
visibility either because of enforcement
outcomes or due to significant interventions
where we have taken the view that there
have been major regulatory failures. The
Authority will continue to take a path of
reasonable remediation (and we have had a
number of successful outcomes in this
regard) but will not hesitate to look at
enforcement options where matters warrant.
This is part of being a responsible regulator
and maintaining confidence in the
regulatory system.
“The last year under review also
saw significant work effort
around the Beneficial Ownership
Act and defining the Authority’s
role relative to the Act. “
Although not the sponsor of the Bill, the
Authority was a frequent subject matter
contributor to its development, facilitating
discussions with industry and developing
appropriate guidance. This upcoming year
will focus on the oversight role that the
Authority has been given.
Looking inward we have made some
structural realignments to enhance our
supervisory capability in key risk areas and
strengthen our own internal governance.
This has resulted in some role changes for
our Executive team and in some cases the
forging of new relationships with our
regulated community. We have also paused
to consider our supervisory approach during
this period and how we undertake the
programme of supervision across the
Authority. In the upcoming supervisory
cycle, we will be making more use of annual
Isle of Man Financial Services Authority Annual Report 2016/17 • 5