The Isle of Man Financial Services Authority has published the Specified Non-Profit Organisations (Countering the Financing of Terrorism) Code 2026, finalizing the framework consulted on earlier in 2026. Effective Sept. 1, the code replaces the 2019 anti-money laundering and countering the financing of terrorism code and focuses specifically on terrorist financing risks. It applies to specified non-profit organizations that disburse funds to beneficiaries or partner organizations in higher-risk jurisdictions, including through intermediaries or onward remittance arrangements. Covered organizations must adopt senior management-approved, risk-based procedures and controls, complete and regularly review a specified activity risk assessment, understand and monitor relevant beneficiaries and partner organizations, and apply enhanced measures where terrorist financing risk is higher. The code also requires sanctions screening, suspicious activity reporting to the Financial Intelligence Unit, annual staff training and five-year record retention. Breaches constitute criminal offenses. To support implementation, the authority has issued an SNPO Handbook and a customizable specified activity risk assessment template, alongside its consultation feedback statement. The code remains subject to completion of Tynwald's negative procedure in November 2026.
2026-08-26Isle of Man Financial Services Authority
Isle of Man Financial Services Authority publishes new terrorist financing code and guidance for specified non-profit organisations effective September 1
The Isle of Man Financial Services Authority has published a new terrorist financing code and guidance for specified non-profit organisations, effective September 1, 2026. The code requires risk assessments, relationship checks, enhanced measures, ongoing monitoring, suspicious activity reporting, annual training and five-year record retention. It replaces the 2019 code and remains subject to the Tynwald negative procedure in November 2026.