Changes aim to protect hard-working volunteers and their charities (Press Release)

A package of measures, including legislative updates, is being developed by the Financial Services Authority and Department of Home Affairs aimed at protecting Isle of Man charities that work overseas from the possibility of abuse by terrorist groups.

The changes will enable the Island's authorities to assess risks and apply sensible, proportionate safeguards while not discouraging legitimate charitable activities that have such a positive impact on society both locally and internationally.

A consultation launched today, Monday 19 January 2026, on the Government Engagement Hub is inviting feedback on plans to modernise the Island's Countering the Financing of Terrorism (CFT) framework for the Non-Profit Organisation (NPO) sector.

The Isle of Man is renowned for its generosity, with significant sums being raised and distributed every year to local and international good causes. This is reflected in the NPO Terrorist Financing National Risk Assessment, which is scheduled for publication later this month.

The report champions the vital role played by NPOs but recognises the potential for those with international exposure to be exploited by terrorist organisations to raise and transfer funds, often to high-risk countries, under the guise of legitimate charitable activities. Updating the SNPO framework has been identified as an important step in protecting the highly valued work of volunteers and trustees.

The new definition of a Specified Non-Profit Organisation* (SNPO) set out in the draft SNPO (CFT) Code 2026 will result in a slightly broader SNPO population operating under simpler, risk-based requirements, with enhanced support and oversight.

Once the SNPO Code is updated to align with current international standards, the Authority will contact the small number of impacted charities to offer support, including access to free training, dedicated webpages, guidance, FAQs and videos, together with template documents to help them meet the requirements of the Code.

Drop-in sessions for charities and volunteers will take place during the consultation period, with further details to be published in early February.

In line with the current position, any SNPO affected by the changes will not be charged an application or annual fee by the Authority, while training and outreach will be provided from within existing resources.

Minister for Justice and Home Affairs, Jane Poole-Wilson MHK, said: 'I am grateful for all the energy, commitment and hard work undertaken by volunteers, fundraisers and the people of our Island who so generously donate to good causes to benefit those less fortunate on-Island and overseas.'

She added: 'While there have been no cases of terrorist financing involving Isle of Man charities, this consultation is part of a wider body of work aimed at staying ahead of the risks. The proposals seek to protect our volunteers from terrorists and terrorist financiers who may be trying to abuse our NPO sector. Significant support will be available to help our charities and volunteers and ensure a smooth transition to the updated SNPO Code.'

Consultation responses can be provided via the 'Online Survey' link on the Engagement Hub. Alternatively, written feedback should be sent to Dylan Pycroft, Manager - AML/CFT Supervision Division, Financial Services Authority, PO Box 58, Finch Hill House, Bucks Road, Douglas, IM99 1DT, email: [email protected]. The closing date for submissions is Monday 2 March 2026.

Notes:

• *SNPO refers to a body corporate or other legal person, the trustees of a trust, a partnership, a foundation, other unincorporated association or organisation or any equivalent or similar structure or arrangement established solely or primarily to raise or disburse funds for purposes like charitable, religious, cultural, educational, social, fraternal or philanthropic purposes with the intention of benefitting the public or a section of the public, or for the carrying out of other types of "good works" which -

raises funds from outside the Isle of Man, the Bailiwick of Jersey, the Bailiwick of Guernsey, the United Kingdom, and the Republic of Ireland; or

disburses funds to one or more ultimate recipients outside the Isle of Man, the Bailiwick of Jersey, the Bailiwick of Guernsey, the United Kingdom, and the Republic of Ireland; and

where the decision of where to disburse the funds is made within the Island.

• The Isle of Man operates a two-tier risk-based oversight regime for NPOs. All registered NPOs are subject to oversight by HM Attorney General's Chambers to ensure transparency, financial accountability and governance. A sub-set of the NPO population identified as potentially higher risk based on specific criteria are subject to oversight by the FSA in respect of compliance with the Island's AML/CFT regime.

• Specified Non-Profit Organisations (Countering the Financing of Terrorism) Code 2026 will replace and revoke the Anti-Money Laundering and Countering the Financing of Terrorism (Specified Non-Profit Organisations) Code 2019.

• In accordance with the Designated Businesses (Fees) Order 2023, SNPOs incur no application or annual fees with the FSA. There are no plans to change this in the future. The only anticipated (non-financial) impact, is additional time that SNPO trustees may need to spend adhering with the Code and interacting with the FSA. If a charity is supported by a TCSP/Accountant, additional charges might be applied by the TCSP/Accountant if there is a commercial arrangement in place.