IOM FSA Publishes Findings of Phase 1 “ALL INDUSTRY” BRA Thematic Review

On: 08 December 2025 - The Isle of Man Financial Services Authority has published the findings from Phase 1 of a thematic review relating to the Business Risk Assessment (“BRA”), as required by paragraph 5 of the Anti-Money Laundering and Countering the Financing of Terrorism Code 2019 (“the Code”).

Following the completion of the BRA thematic in 2023/2024, which focused on the Trust and Corporate Service Provider (“TCSP”) sector, this cross-sectoral review aims to build on those initial observations and best practices.

• PHASE 1 - JULY 2023 https://www.iomfsa.im/media/3180/tcsp-thematic-report-phase-1.pdf
• PHASE 2 - JAN 2024 https://www.iomfsa.im/media/3232/tcsp-thematic-report-phase-2.pdf

The Authority is reviewing the extent to which relevant persons have assessed their exposure to risks such as money laundering (“ML”), terrorist financing (“TF”) and proliferation financing (“PF”), with a specific focus on how firms analyse, mitigate and document their BRA risks effectively, applying the preventative measures set out in the Code.

As part of Phase 1, information on the BRA was gathered via a questionnaire issued earlier this year to 30 supervised entities across various sectors.

The Phase 1 report, available online,

• Sets out each question and the responses submitted.
• Provides the Authority’s observations on the data, examples of best practice, and a direct comparison with the results from the Phase 1 TCSP BRA Thematic 2023.

Phase 2 of the project, which includes desk-based inspections of selected entities’ BRAs, is in progress, with results expected to be published in 2026.

Kinga Chmielowska, a Manager in the AML/CFT Supervision Division and lead for the project, said

• ‘The report shares valuable insight into the data collected as part of Phase 1 of the project, with analysis of the data against the previous questionnaire results issued in 2023.
• A practical business risk assessment is vital in risk management. It provides relevant persons with a structured understanding of the ML/FT/PF risks they face and the extent of their exposure, enabling the necessary controls to be implemented to mitigate those risks.
• ‘We encourage all supervised entities to read the Phase 1 report and take any required action to ensure their own BRA is robust and up-to-date, with the assessment having due regard to all the prescribed risk factors of paragraph 5(3) of the Code.’

SOURCES

https://www.iomfsa.im/fsa-news/2025/dec/authority-publishes-findings-of-phase-1-bra-thematic-review/

https://www.iomfsa.im/media/3535/bra-thematic-phase-1-report.pdf