Specified Non-Profit Organisations (Countering the Financing of Terrorism) Code 2026

Overview

The Department of Home Affairs and Financial Services Authority are jointly seeking views on the proposed draft Specified Non-Profit Organisations (Countering the Financing of Terrorism) Code 2026 (the 'SNPO Code 26'). This consultation seeks to gauge the Island’s non-profit organisations ('NPO') sector’s opinion on the proposed draft.

The draft Code is offered for public consultation now, for a period of 6 weeks, in order that views can be received on the legislation prior to progression through the legislative process.

The SNPO Code 26 is intended to revoke and replace the Anti-Money Laundering and Countering the Financing of Terrorism (Specified Non-Profit Organisations) Code 2019 ('SNPO Code 19').

The SNPO Code 26 seeks to simplify the CFT requirements that specified non-profit organisations ('SNPOs') are subject to, allowing SNPO resource to focus on continuing to carry out ‘good works’ from the Island, whilst still ensuring that SNPOs have CFT measures robust enough to safeguard their organisations from falling vulnerable to terrorist financing.

The SNPO Code 26 refers to a new definition of ‘SNPO’, which will be amended in both Schedule 4 to the Proceeds of Crime Act 2008 ('POCA') and Schedule 1 to the Designated Businesses (Registration and Oversight) Act 2015 ('DBRO'). The new definition widens the scope of what will be considered an SNPO, and will, therefore, bring a number of NPOs under both the requirement to register with the Isle of Man Financial Services Authority as a Designated Non-Financial Business or Profession ('DNFBP')¹, whilst also subjecting them to the CFT requirements contained within the SNPO Code 26.

¹ Please note that SNPOs are exempt from paying application and annual fees, as per the Designated Businesses (Fees) Order 2023.

Why your views matter

The reasons for this new Code are two-fold:

1. The Authority has, through its engagement with the Island’s existing SNPOs, taken on-board the feedback from the sector around the practicalities of compliance with the SNPO Code 19. As such, the Authority wishes to revise the requirements in order to ensure that the expectations around CFT measures SNPOs are required to undertake are practical and manageable for the Island’s sector
    
2. Ahead of the Island’s Mutual Evaluation by MONEYVAL in 2026, the Authority intends to ensure that the Island’s legislative framework around NPOs is fully aligned with Recommendation 8 of the Financial Action Taskforce’s 40 Recommendations (the 'international standards'). Recommendation 8 focusses on how countries should ensure that NPOs are protected from terrorist financing. There have been a number of changes to the international standards in recent years, particularly in relation to Recommendation 8 – CFT measures must be risk-based and not so burdensome as to dissuade organisations from carrying out ‘good works’

Reasonable adjustments and alternative formats

The Department and the Authority are committed to equal opportunities and our aim is to make our documents easy to use and accessible to all.

The Department will take steps to accommodate any reasonable adjustments and provide such assistance as may reasonably be required to enable access or reply to this consultation.

If this document is required in another format or assistance is required with accessing or replying to this consultation, please email amlpolicy@iomfsa.im

If you have a query in relation to how this consultation has been carried out, please contact the Authority’s AML/CFT Supervision Division by email at amlpolicy@iomfsa.im or by telephone on +44 1624 646000.

Responding to this consultation and questions

Open dialogue with stakeholders is an essential element for successful development of the Authority’s proposals. Constructive feedback will help the Authority reach an informed decision on the content of the proposals and manner of implementation. Respondents should note the following when responding to this consultation:

• Submissions received by the closing date will be considered but may not necessarily result in a change to the proposals following a review of all responses received

Following closure of the consultation period on 2 March 2026, the Authority will review the responses received and publish a Feedback Statement on the Engagement Hub and the Authority’s website.

This consultation can be responded to by clicking on the 'Online survey' link below.

Alternatively you can download a paper version of this consultation from the 'Related' section below and email it to Dylan.pycroft@iomfsa.im or post it to:

Mr Dylan Pycroft,
Manager – AML/CFT Supervision Division,
Isle of Man Financial Services Authority,
PO Box 58,
Finch Hill House,
Bucks Road,
Douglas,
Isle of Man,
IM99 1DT

Events

Specified Non-Profit Organisations – Terrorist Financing Consultation

The Authority is planning to hold an event, open to NPOs (including SNPOs) which may be affected by the proposed changes. Further details to be announced shortly. Please reach out to snpo@iomfsa.im should you wish to register your interest.