Guidance for the AML/CFT Nationality Return - STRIX

Guidance Issued: 06 December 2024 Version 3
Guidance for the
AML/CFT Nationality
Return - STRIX
Contact: AML/CFT Supervision Division amlreturns@iomfsa.im Isle of Man Financial Services Authority Finch Hill House, Bucks Road, Douglas, IM99 1DT

Guidance for the AML/CFT Nationality Return – STRIX Page 1 About this Guidance Purpose The need to collect this data was identified during the National Risk Assessment and recent mock evaluation to better inform the overall picture of risk and enhance the Island’s enhance the Island’s risk understanding. The information will be critical in terms of demonstrating the nationality of customers serviced by Island firms, which may include members of the British expat community. This guidance document is designed to further assist firms with the completion of the Isle of Man Financial Services Authority (“the Authority”) Nationality Data Return within the STRIX system. It gives firms the full list of questions and data being requested, guidance around the questions and in some areas the required format of the requested values. The format used in this document is as follows:
Question
Number
Question Reference number
Should you have any further questions or queries which are not covered in this guidance, please contact the AML/CFT Supervision Division by email – amlreturns@iomfsa.im These questions will be integrated into the wider AML/CFT Data Return in January 2027. Nationality Nationality Data Collection Q1 Does the firm have any natural person customers? 1.1.1 If you haven’t had any natural person customers in the date range, answer no to this question and submit the return. No further information is required. If you answer Yes to this question, Q2 appears for completion. For the below questions, input the total number of natural person customers as at the end of the reporting period (as at the 31st December), categorised by each nationality. Zero returns do not need to be included. For clarity, the total number of natural person customers should include all existing customers, including any new customers on-boarded in the reporting period. ‘Customers’ should be interpreted as per the definition in the Code. For the avoidance of doubt, ‘customers’ in the above questions refers to all customers of the firm who are natural persons, irrespective of the services provided.

Guidance for the AML/CFT Nationality Return – STRIX Page 2 Q2 For each jurisdiction in which a customer holds a nationality, please indicate the number of natural person customers associated with each jurisdiction for their first nationality. 1.1.2 You will be presented with a numeric box with the ability to assign values to the ISO list of countries. For instance, if your customer base is made up of 65 customers with the following breakdown of nationalities:
Country of Nationality Volume of Customers
United Kingdom 50
Greece 10
France 5
Argentina 0
Ignoring the zero values, you would enter the following data:
There is no mandated order for the list of nationalities and can be input in any order you choose. Q3 Sum of Customers First Nationality 1.1.3 The Strix system will conveniently provide you with a total of the 1st Nationality. This total must match the total number of Natural Person Customers submitted in the 2025 AML/CFT Return and may result in the survey being rejected. If there is any discrepancy this should be noted in the available comment field. Q4 Do any of your natural person customers hold a second nationality? 1.14 Some firms will have customers who have more than one nationality, if you have customers who have more than one, answer yes to this question, and Q4 will appear.

Guidance for the AML/CFT Nationality Return – STRIX Page 3 Q5 For each jurisdiction in which a customer holds a second nationality, please indicate the number of natural person customers associated with each jurisdiction for their second nationality. 1.1.5 This question is identical in format to Q2 but is to be used to capture the second nationality. If your customer base was represented as the following:
Country of Nationality Count of 1st
Nationalities
Count of 2nd
Nationalities
United Kingdom 50 10
Greece 10 0
France 5 3
Argentina 0 0
Germany 0 1
Netherlands 0 1
You would enter the following data:
Q6 Do any of your natural person customers hold a third nationality? 1.1.6 As for Q3/Q4, Q5 is designed to capture the data of those customers who have more than two nationalities. Answering Yes to this question will cause Q6 to appear. Q7 For each jurisdiction in which a customer holds a third nationality, please indicate the number of natural person customers associated with each jurisdiction for their third nationality. 1.1.7 Similar to the above, if your customer base was represented by the following:
Country of
Nationality
Count of 1st
Nationalities
Count of 2nd
Nationalities
Count of 3rd
Nationalities
United Kingdom 50 10 1
Greece 10
France 5 3 0
Argentina 0
Germany 0 1 0
Netherlands 0 1 0
Japan 0 0 1

Guidance for the AML/CFT Nationality Return – STRIX Page 4 You would enter the following data:
Q8 Do you have any natural person customers with more than three nationalities? 1.1.9 Q9 If you have customers with more than three nationalities, please provide a narrative below of the numbers and circumstances. 1.1.10 It is accepted that in rare occasions a customer may have more than three nationalities; in this case please provide a narrative of the number and if possible, a list of other countries as well as any supporting information in your understanding around the rationale for this number of nationalities. Q10 Do you have any further comments on this survey, or narrative for the above submissions? 1.1.11 Q11 [Comment Box for Q10] 1.1.12 Use this question to provide further comments if necessary. Further Information and Support For any clarification, please contact the AML Returns team in the AML/CFT Supervision on amlreturns@iomfsa.im.