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The Isle of Man Financial Services Authority's approach to enforcement

12/05/2025

Bettina Roth, Chief Executive, Isle of Man Financial Services Authority [THE FSA]  on LinkedIn provided a view on the FSA's approach to enforcement, as follows:-

  • The FSA takes a risk-based approach to supervision, with engagement proportionate to a firm’s size, the type of activity it conducts, and its potential to disrupt the Island’s financial system.
  • Where the FSA supervisory activities identify issues, the FSA work with the firm to return it to a compliant position.
  • Remediation is a key part of the FSA toolkit and covers a wide range of options, such as additional reporting, focused inspections, and the use of directions.
  • The FSA pursue enforcement action when it is proportionate, reasonable, and appropriate.
  • Statistics show that
    • The FSA conducted 725 inspections during the 2023/24 financial year.
    • Of these, five matters were referred to the FSA Enforcement Division for possible investigation and three matters to Enhanced Supervision.
  • Where a discretionary civil penalty is issued, this is calculated as a percentage of the firm’s relevant (annual) income.
  • The FSA also consider any mitigating circumstances.
  • The FSA do not set targets for income from penalties and does not operate any staff bonus or performance-related incentive schemes linked to the FSA enforcement action or the imposition of penalties.
  • The FSA's approach to enforcement was highlighted as part of a presentation at this year’s Manx State of the Nation Conference.
  • The FSA also published a Q&A document to respond to some common themes on a range of key topics.

SOURCE

  1. https://www.linkedin.com/posts/bettina-roth-09b2152_powerpoint-presentation-activity-7326264049204170752-Pg0h?utm_source=share&utm_medium=member_desktop&rcm=ACoAAAA_6EIB0wPAWyjQcuq_XiD3asUV8xpMeZ0
  2. Presentation: https://www.iomfsa.im/media/3411/manx-state-of-the-nation-presentation-2025.pdf 
  3. Q&A document: https://www.iomfsa.im/media/3412/mson-qa-2025.pdf 
IOM

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