Isle of Man Financial Services Authority imposes GBP 1.95m AML/CFT civil penalty on RL360

The Isle of Man Financial Services Authority published a public statement imposing a civil penalty of GBP 1,950,000 on RL360 Insurance Company Limited and RL360 Life Insurance Company Limited, after an inspection identified contraventions of the Anti-Money Laundering and Countering the Financing of Terrorism Code 2019. The penalty was set at GBP 2,785,714 and discounted by 30%, with the Authority citing RL360’s cooperation, early settlement and operational changes to remediate issues. The inspection (conducted in February 2023) found deficiencies in RL360’s Business Risk Assessment and Customer Risk Assessment, including inadequate methodology and incorrect classification of high-risk customers. It also identified gaps in onboarding due diligence evidence, insufficient ongoing monitoring and trigger event reviews for high-risk customers, and weak Customer Due Diligence and Enhanced Customer Due Diligence records, including for politically exposed persons and evidencing source of funds and wealth. Further shortcomings included failure to follow internal policies (such as annual reviews for high-risk customers) and inadequate documentation and consideration of relationships linked to high-risk jurisdictions. RL360 has undertaken an extensive remediation programme and continues to enhance internal processes and procedures, while the Authority noted that the remediation has not materially changed the firm’s risk profile.