Beneficial Ownership Amendment

The Isle of Man Financial Services have recently sought to raise awareness regarding the addition of a new category, Control as Liquidator.

The Authority is responsible for overseeing compliance with the Beneficial Ownership Act 2017 (amended 2021) and has noted a degree of confusion with the Money Laundering Reporting Officers as to whether a liquidator could or should be recorded in the Database therefore this option has been added to clarify this area.

Once the liquidator is appointed the mind and management of the company is vested with them who will typically be in a position in which they are capable of exercising significant control over the company. Relevant persons will be required to determine whether this control meets the threshold of a registrable beneficial owner (being 25%+ of the total control exerted on the company).

A reminder of the the two main roles of the Money Laundering Reporting Officer (MLRO) under the regulations are:

  • the nominated officer, who is responsible for receiving internal suspicious activity reports (SARs), assessing whether there is a suspicion or not, and then sending those suspicions to the National Crime Agency; and
  • where appropriate to the size and nature of the business, a member of senior management who is responsible for overall compliance with the Anti-Money Laundering (AML) regime – this individual oversees policies and procedures, including ensuring there is a firm wide risk assessment, staff are trained and competent, and compliance reviews are effective.

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