2021-01-07
The Isle of Man Financial Services Authority issued this thematic feedback to address governance, compliance, and risk management deficiencies identified in Exempt and Exempt-type schemes. The review highlights critical failures among Class 3 Licenceholders, including inadequate adherence to scheme particulars, weak functionary agreements, and insufficient Anti-Money Laundering and Countering the Financing of Terrorism controls. Regulated entities are required to implement robust internal controls, ensure accurate documentation of delegated AML/CFT obligations, and maintain active oversight of scheme operations to meet regulatory expectations.