IoM Issues Money Laundering Guidance
by Jason Gorringe, Lowtax.net, London
26 January, 2017
The Customs and Excise Division of the Isle of Man Treasury has published further money laundering guidance.
The guidance deals with the treatment of "false positive" matches when using screening software or other checks of client and account databases to detect persons or entities subject to UN or EU sanctions.
A false positive happens when there is an apparent match to a target on a sanctions list where, after further investigation, it is decided they are not, in fact, the designated target of the sanctions.
An amendment to Sanctions Notice 26, which provides general information about the various sanctions regimes, makes it clear that a business should have a process detailing how it carries out checks to confirm or treat a match as a false positive, and maintain a record of any false positives as well as the records of actual matches and attempted transactions, among other things.
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