IOM FIU BRIBERY Typology [Feb 2026}

The Isle of Man Financial Intelligence Unit (FIU) produces monthly typologies as part of its strategic objective to improve the regulated sectors' understanding of financial crime risks.

Typologies produced by the FIU support the Island’s international obligations under FATF recommendation 29, which requires Financial Intelligence Units to develop and disseminate information that helps identify and assess threats related to money laundering (ML) and associated predicate offences.

The typologies and indicators presented here are based on: Þ Analysis of suspicious activity reports (SARs) received by the FIU, Þ Open-source intelligence (OSINT).

The example below is fictional and particularly relevant to professionals working in the TCSP sector.

PURPLE TCSP

• Purple TCSP is an Isle of Man-based Trust and Corporate Service Provider. Purple TCSP were approached by Blue TCSP, located in another jurisdiction.
• Purple TCSP were asked to provide administrative services to an Isle of Man company that owns a UK property.
• This company was previously administered by another Isle of Man TCSP - Blue TCSP

BLUE TCSP

• Blue TCSP were evasive when asked to confirm the reason services were terminated, stating it was due to a fee dispute when pressed. 
• The company is ultimately owned through a Trust in another jurisdiction. Purple TCSP requested that Blue TCSP provide due diligence for the ownership structure. 
• Mrs Red was initially stated by Blue TCSP to be the Settlor of the Trust. Purple TCSP identified from the documentation provided that the Trust was settled with an interest-free loan from her father, Mr Green.
• Blue TCSP were evasive when asked to provide a detailed source of wealth documentation for Mr Green.

PURPLE TCSP CDD/EDD

• Purple TCSP conducted OSINT on Mr Green and identified that he is the owner of a construction contracting company in another jurisdiction that is undertaking work for a large government contract.
• Mr Green was identified to be a commercially exposed person (CEP).
• Further OSINT showed this contract was awarded directly by a politician linked heavily to international corruption offences.
• Social media accounts identified that Mr Green was associated with this politician outside of a commercial environment.

What happens next

• Purple TCSP declined the business.
• Purple TCSP suspected Mr Green may have bribed a foreign politician to acquire a lucrative government contract for his company.
• Purple TCSP further suspected that the assets of the Trust had been purchased or tainted with the proceeds of corruption.
• Purple TCSP submitted a Suspicious Activity Report to the FIU.

Sources  

• https://tinyurl.com/yc5wjpn5
• https://tinyurl.com/bdfty36x
• https://www.linkedin.com/posts/isle-of-man-financial-intelligence-unit_february-2026-monthly-typology-activity-7435689902006091778-DXx3?utm_source=share&utm_medium=member_ios&rcm=ACoAAAA_6EIB0wPAWyjQcuq_XiD3asUV8xpMeZ0
• https://media.licdn.com/dms/document/media/v2/D4E1FAQHeFRSMqninXQ/feedshare-document-pdf-analyzed/B4EZzDgbQAHgAY-/0/1772806585057?e=1773878400&v=beta&t=oyg6qde30w-2odzPPMV4sfgSmBLZiyVNJAgHnD8TD0c