ICLG - Anti-Money Laundering Laws and Regulations - Isle of Man Chapter covers issues including criminal enforcement, regulatory and administrative enforcement and requirements for financial institutions and other designated businesses.
1.1 What is the legal authority to prosecute money laundering at the national level?
The legal authority to prosecute money laundering at the national level is the Proceeds of Crime Act 2008 (“POCA”). This is very similar in content to the UK Proceeds of Crime Act and received Royal Assent on 21 October 2008.
1.2 What must be proven by the government to establish money laundering as a criminal offence? What money laundering predicate offences are included? Is tax evasion a predicate offence for money laundering?
POCA states that money laundering is an act that: (a) constitutes an offence under section 139, 140 or 141; (b) constitutes an attempt, conspiracy or incitement to commit an offence specified in paragraph (c); (c) constitutes aiding, abetting, counselling or procuring the commission of an offence specified in paragraph (a); or (d) would constitute an offence under paragraphs (a), (b) or (c) if committed on the Island. A section 139 offence regards concealing, disguising, converting, transferring or removing criminal property from the Island. A section 140 offence regards becoming concerned in an arrangement which the person knows, or suspects facilitates (by whatever means), the acquisition, retention, use or control of criminal property by or on behalf of another person. A section 141 offence regards acquiring, using or having possession of criminal property. Property is criminal if: (i) it constitutes a person’s benefit from criminal conduct or represents such a benefit (in whole or in part and whether directly or indirectly); and (ii) the alleged offender knows or suspects that it constitutes or represents such a benefit. Criminal conduct is conduct that: (a) constitutes an offence in the Island; or (b) would constitute an offence in the Island if it occurred there.
POCA does not specify which predicate offences are included, but as the predecessor legislation extended to all crimes, POCA would apply to any crime which generated money to be laundered. This is inclusive of tax evasion.
1.3 Is there extraterritorial jurisdiction for the crime of money laundering? Is money laundering of the proceeds of foreign crimes punishable?
There are provisions within POCA for enforcement of a confiscation order where the property in question is outside of the Island, or there may be evidence of criminal conduct outside the Island. There are also provisions for co-operation with external authorities who make requests for assistance. As set out in question 1.2, if the criminal conduct occurred outside of the Island, it is punishable if the criminal conduct would constitute an offence in the Island if it occurred there.
1.4 Which government authorities are responsible for investigating and prosecuting money laundering criminal offences?
It is the responsibility of the Economic Crime Unit to investigate money laundering offences, which then in turn passes the information to the Attorney General’s Chambers for prosecution (as applicable).
1.5 Is there corporate criminal liability or only liability for natural persons?
Section 221 of POCA states that where an offence under the Act is committed by a body corporate and it is proved that the offence: (a) was committed with the consent and connivance of an officer of the body; or (b) was attributable to neglect on the part of an officer of the body, the officer, as well as the body, shall be guilty of the offence.
There is also corporate criminal liability under the Anti-Money Laundering and Countering the Financing of Terrorism Code 2019 (the “Code”). The Code is a piece of secondary legislation made under POCA which requires relevant businesses to have anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) procedures and controls in place.
1.6 What are the maximum penalties applicable to individuals and legal entities convicted of money laundering?
A person guilty of an offence as set out in question 1.2 above is liable: on summary conviction to custody for a term not exceeding 12 months, or to a fine not exceeding £5,000, or both; or on conviction on information, to custody for a term not exceeding 14 years, or to a fine, or both.
1.7 What is the statute of limitations for money laundering crimes?
There are no limitation periods attached to money laundering offences under POCA.
1.8 Is enforcement only at national level? Are there parallel state or provincial criminal offences?
Enforcement is only at national level, there are no provisions for state or provincial offences associated with the Isle of Man.
1.9 Are there related forfeiture/confiscation authorities? What property is subject to confiscation? Under what circumstances can there be confiscation against funds or property if there has been no criminal conviction, i.e., non-criminal confiscation or civil forfeiture?
POCA provides for recovery orders, property freezing orders, interim receiving orders, recovery of cash, confiscation orders and restraint orders.
Proceedings for a recovery order may be taken by the Attorney General in the High Court against any person whom the Attorney General thinks holds recoverable property. There are extensive provisions in POCA as to what is and is not recoverable property, but, in essence, it is property obtained through unlawful conduct.
Where the Attorney General may take proceedings for a recovery order in the High Court, the Attorney General may apply to the court for a property freezing order. He may also apply for an interim receiving order.
There are provisions for the seizure and detention of cash if a customs officer or police constable suspects that the cash is recoverable property or is intended for use by any person in unlawful conduct.
The Court of General Gaol Delivery can make a confiscation order if it (a) decides that the defendant has a criminal lifestyle and has benefitted from his or her general criminal conduct, or (b) decides that the defendant does not have a criminal lifestyle and has benefitted from his or her particular criminal conduct. POCA does contain provisions as to what constitutes a criminal lifestyle and what constitutes conduct and benefit.
The Court of General Gaol Delivery can make a restraint order, subject to a condition for such an order being in place, prohibiting any specified person from dealing with any realisable property held by that person. Realisable property is itself defined in POCA.
Conduct occurring in the Island is unlawful conduct if it is unlawful under the criminal law. Conduct which occurs outside the Island and would be unlawful under the criminal law of the particular country and the criminal law of the Island is also unlawful conduct. The court must decide on a balance of probabilities whether it is proved that (a) any matters alleged to constitute unlawful conduct have occurred, or (b) any person intended to use any cash in unlawful conduct.
1.10 Have banks or other regulated financial institutions or their directors, officers or employees been convicted of money laundering?
There have not been any recent convictions for money laundering. The Council of Europe body MONEYVAL, of which the Isle of Man is a member, said in its 2017 report that the Island had a modest rate of convictions, and this was identified as a weakness in the Island’s AML/CFT regime. Therefore, it is anticipated that the authorities will seek opportunities to bring prosecutions where possible.
1.11 How are criminal actions resolved or settled if not through the judicial process? Are records of the fact and terms of such settlements public?
In some circumstances, criminal actions can be resolved outside of the judicial process by way of settlement agreements, similar to the Deferred Prosecution Agreements introduced in the UK. Whilst the agreements are typically private, any hearing of the court to sanction or approve the agreement may be open to the public.
In addition to the criminal offence of Money Laundering, the Anti-Money Laundering and Countering the Financing of Terrorism (Civil Penalties) Regulations 2019 allow for the imposition of a fine for money laundering or terrorist financing-related failings.
1.12 Describe anti-money laundering enforcement priorities or areas of particular focus for enforcement.
The Isle of Man Financial Services Authority (the “FSA”) stated that enforcement action focus is on intervening at an early, and justified, stage to help prevent unacceptable risks from crystallising. The FSA states that it seeks to understand, collaborate and follow a reasonable path of remediation to achieve the right outcomes, and enforcement is pursued where proportionate, reasonable and appropriate. A politically exposed person (“PEP”) thematic review was carried out between 2021 and 2023 to understand the risks posed to the Isle of Man. The review was split into phases – Phase one included data collection and analysis of AML/CFT returns and a questionnaire, while Phase two consisted of onsite inspections.
In December of 2023, the FSA published a report as a result of the thematic review. The purpose of the report is to offer suggestions of good practice to all firms and in turn, support the Isle of Man’s ability to meet international standards in combating bribery and corruption involving PEPs.
2.1 What are the legal or administrative authorities for imposing anti-money laundering requirements on financial institutions and other businesses? Please provide the details of such anti-money laundering requirements.
Aside from primary legislation (POCA, the Anti-Terrorism and Crime Act 2003 and the Terrorism and Other Crime (Financial Restrictions) Act 2014), the Code, as referred to in question 1.5, also imposes AML requirements on financial institutions and other businesses. In addition, the FSA, which is the principal supervisor of financial institutions and designated non-financial businesses and professions (“DNFBPs”), has issued a comprehensive AML/CFT Handbook (the “Handbook”) as well as sector-specific guidance, both of which are deemed persuasive guidance for the purposes of evidencing compliance with the Code.
The Gambling Supervision Commission (the “GSC”) is the principal supervisor of the e-gaming and terrestrial gaming sector. Whilst the primary legislation applies equally to the gambling sector, there is a gaming-specific version of the Code in addition to a separate AML/CFT Handbook issued by the GSC.
2.2 Are there any anti-money laundering requirements imposed by self-regulatory organisations or professional associations?
It is likely that professional associations in the accountancy sector impose AML restrictions on member firms in the Isle of Man. As these requirements are UK-based, and do not take account of Isle of Man AML/CFT legislation and regulation, compliance with the Isle of Man standards will normally ensure compliance with any UK-based standards. Island members of such professional associations would normally look to the FSA’s Handbook and sector-specific guidance for the standards of conduct expected.
2.3 Are self-regulatory organisations or professional associations responsible for anti-money laundering compliance and enforcement against their members?
The FSA is the principal supervisor of all financial institutions and DNFBPs. Although supervision, through onsite visits to some DNFBPs, has been delegated to the self-regulatory organisations or professional associations with which the FSA has a Memorandum of Understanding, the FSA remains ultimately responsible for enforcement.
2.4 Are there requirements only at national level?
Due to the size of the Isle of Man, requirements are only at national level.
2.5 Which government agencies/competent authorities are responsible for examination for compliance and enforcement of anti-money laundering requirements? Are the criteria for examination publicly available?
The FSA is responsible for the examination of compliance and the enforcement of AML requirements for financial institutions and DNFBPs. The GSC is responsible for the examination of compliance and the enforcement of AML requirements for gaming operators. Normally, the FSA’s supervisory approach is publicly available, while that of the GSC does not appear to be publicly available.
2.6 Is there a government Financial Intelligence Unit (“FIU”) responsible for analysing information reported by financial institutions and businesses subject to anti-money laundering requirements?
There is a Financial Intelligence Unit (“FIU”) under the direction of a Board comprising of the Attorney General, the Chief Constable and the Collector of Customs and Excise. Financial institutions, DNFBPs and gaming operators are all required to report to the FIU via the online reporting system, THEMIS.
2.7 What is the applicable statute of limitations for competent authorities to bring enforcement actions?
There is no prescribed limitation upon which a competent authority must bring enforcement actions under legislation.
2.8 What are the maximum penalties for failure to comply with the regulatory/administrative anti-money laundering requirements and what failures are subject to the penalty provisions?
A breach of the Code or its gaming equivalent carries a penalty of: (a) on summary conviction, custody for a term not exceeding 12 months or a fine not exceeding £5,000, or both; or (b) on conviction on information, custody not exceeding two years or a fine, or both. The FSA has powers under the Financial Services (Civil Penalties) Regulations 2015 and the Anti-Money Laundering and Countering the Financing of Terrorism (Civil Penalties) Regulations 2019 to levy a civil penalty. Where there is a Level One issue (risk of loss), the FSA can fine the licence holder up to 5% of relevant income. Where there is a Level Two issue (actual loss), the FSA can fine the licence holder up to 8% of relevant income. The Financial Services Act 2008 gives the FSA a range of additional powers that could be used in the event of AML/CFT compliance failures, including where a lack of fitness and propriety is demonstrated, imposing prohibitions, and, ultimately, the revocation of a licence.
The Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Act 2019 provides the GSC with similar powers to the FSA, including the ability to levy civil penalties. The 2019 Civil Penalties Regulations do not extend to the GSC.
2.9 What other types of sanction can be imposed on individuals and legal entities besides monetary fines and penalties?
The FSA and the GSC have a range of sanctions available to them, including the restriction of activities, licence conditions, directions, public statements, injunctions, warning notices, appointment of skilled persons, prohibitions and licence revocation.
2.10 Are the penalties only administrative/civil? Are violations of anti-money laundering obligations also subject to criminal sanctions?
A breach of the Code would be considered a criminal offence, as would any offence under the primary legislation.
2.11 What is the process for assessment and collection of sanctions and appeal of administrative decisions? a) Are all resolutions of penalty actions by competent authorities public? b) Have financial institutions challenged penalty assessments in judicial or administrative proceedings?
There is an appeal process set out in the Financial Services Act 2008 in relation to decisions made by the FSA, and a Financial Services Tribunal which would hear any appeal. Some measures taken by the FSA, such as a warning notice, might not be made public, but an appeal to the Tribunal would usually be in the public domain. Similarly, there is a Gambling Appeals Tribunal that hears any appeal under the Gambling (Anti-Money Laundering and Countering the Financing of Terrorism) Act 2019.
3.1 What financial institutions and non-financial businesses and professions are subject to anti-money laundering requirements? Describe any differences in the anti-money laundering requirements that each of them are subject to.
Schedule Four to POCA sets out which types of businesses qualify as a “business in the regulated sector” for the purposes of POCA and the Code. There is a wide range of businesses captured, including the traditional financial services sector (banking, insurance, funds), as well as the gaming sector (online and terrestrial), estate agents, lawyers (when they undertake certain types of activities), accountants, corporate and trust service providers, pension providers, money transmission agents, tax advisers, charities, payroll agents and businesses involved with virtual currency.
Where a business is classified as a DNFBP, there is no difference in the AML requirements applied. DNFBPs are still classed as “business in the regulated sector”, meaning the Code is applicable.
3.2 Describe the types of payments or money transmission activities that are subject to anti-money laundering requirements, including any exceptions.
Deposit taking and money transmission services (including payment services) are regulated activities within the Isle of Man. As such, the Code is applicable. Further information on the exclusions available can be found in the Regulated Activities Order 2011.
3.3 To what extent have anti-money laundering requirements been applied to the cryptocurrency industry? Describe the types of cryptocurrency-related businesses and activities that are subject to those requirements.
As per the answer to question 3.1, businesses involved with virtual currency are deemed a business in the regulated sector and must comply with the Code. The wording of section 4 of POCA is widely drawn and encompasses the businesses of issuing, transmitting, transferring, providing safe custody or storage of, administering, managing, lending, buying, selling, exchanging or otherwise trading or intermediating convertible virtual currencies. Such currencies include cryptocurrencies or similar concepts where the concept is accepted by persons as a means of payment for: goods or services; a unit of account; a store of value; or a commodity. Any business that falls under this definition must register with the FSA as a DNFBP, and is subject to the FSA’s supervision for compliance with the Code.
3.4 To what extent do anti-money laundering requirements apply to non-fungible tokens (“NFTs”)?
AML requirements do not apply to NFTs as objects but are rather applied to involved parties. Parties involved with NFTs may be required to register as a designated business and would also be subject to the Code. For example, a business running or operating a token exchange would be required to register as a designated business and would be subject to the Code.
3.5 Are certain financial institutions or designated businesses required to maintain compliance programmes? What are the required elements of the programmes?
Any business that qualifies as a “business in the regulated sector” (see question 3.1 above) is required to comply with the Code. Paragraph 30 of the Code requires such businesses to maintain appropriate procedures for monitoring and testing compliance with the AML/CFT requirements, while ensuring that: (a) the business has robust and documented arrangements for managing the risks identified by the business risk assessment; (b) the operational performance of those arrangements is suitably monitored; and (c) prompt action is taken to remedy any deficiencies in arrangements.
3.6 What are the requirements for recordkeeping or reporting large currency transactions? When must reports be filed and at what thresholds?
In accordance with the Customs and Excise Management Act 1986, Customs and Excise issued Notice 9011 (the “Notice”) in November 2008. The Notice states that if cash in excess of £10,000 is sent to, taken from, brought into or received in the Island, then the person carrying, sending or receiving it must make a declaration to Customs and Excise. This applies to cash going to or coming from anywhere outside the Island, regardless of whether the cash is being carried by someone or is sent in the mail, by courier service or is contained in freight, a vehicle or a vessel. Cash includes any banknotes or coins in any currency (including counterfeit), postal orders and cheques of any kind (including travellers’ cheques), but excluding cheques drawn on a British or Irish bank. It also includes stored value cards, and other documents, devices, coins or tokens with a monetary value.
Paragraph 13 of the Code requires a business in the regulated sector to perform ongoing and effective monitoring of any business relationship, which includes appropriate scrutiny of transactions, paying particular attention to suspicious and unusual activity. Unusual activity is defined in the Code to include large transactions. There is no definition or threshold for what constitutes a large transaction, so each business would have to consider that in the context of their customer relationship.
3.7 Are there any requirements to report routinely transactions other than large cash transactions? If so, please describe the types of transactions, where reports should be filed and at what thresholds, and any exceptions.
There is a requirement to report any suspicious transaction to the FIU.
3.8 Are there cross-border transactions reporting requirements? Who is subject to the requirements and what must be reported under what circumstances?
Aside from the requirements of the Notice set out in question 3.4, Isle of Man financial institutions must also comply with the US Foreign Account Tax Compliance Act and the Common Reporting Standard. These require automatic exchange of information on accounts and balances held by residents of various other jurisdictions. Reporting by Isle of Man financial institutions is to the Isle of Man Income Tax Division, which then exchanges the information with other tax authorities around the world.
3.9 Describe the customer identification and due diligence requirements for financial institutions and other businesses subject to the anti-money laundering requirements. Are there any special or enhanced due diligence requirements for certain types of customers?
The customer due diligence requirements are set out in the Code. These broadly require: (a) the identification of the customer; (b) the verification of the identity of the customer using reliable, independent source documents; (c) the verification of the legal status of the customer using relevant information obtained from a reliable independent source; (d) the obtaining of information on the nature and intended purposes of the business relationship; and (e) the taking of reasonable measures to establish the source of funds. The FSA’s Handbook provides further guidance on each of these areas. Enhanced customer due diligence (“EDD”) must be obtained (a) where a customer poses a higher risk of money laundering or terrorist financing as assessed by the customer risk assessment, or (b) in the event of any unusual activity. EDD is only required for a PEP if there is a higher risk of money laundering or terrorist financing.
3.10 Are financial institution accounts for foreign shell banks (banks with no physical presence in the countries where they are licensed and no effective supervision) prohibited? Which types of financial institutions are subject to the prohibition?
Paragraph 38 of the Code states that a business subject to the Code must not enter into or continue a business relationship or occasional transaction with a shell bank. Such a business must also take adequate measures to ensure that it does not enter into or continue a business relationship or occasional transaction with a respondent institution that permits its accounts to be used by a shell bank.
3.11 What is the criteria for reporting suspicious activity?
Section 142 of POCA creates the failure to disclose an offence on the basis of four conditions being present. These are, in summary: (1) there is knowledge, suspicion or reasonable grounds for knowing or suspecting that another person is engaged in money laundering; (2) that knowledge, suspicion or reasonable grounds came from business in the regulated sector; (3) the identity of the person mentioned in (1) or the whereabouts of the laundered property is known, or there is information that may assist in that regard; and (4) a disclosure is not made to the FIU.
3.12 What mechanisms exist or are under discussion to facilitate information sharing 1) between and among financial institutions and businesses subject to anti-money laundering controls, and/or 2) between government authorities and financial institutions and businesses subject to anti-money laundering controls (public-private information exchange) to assist with identifying and reporting suspicious activity?
Several provisions exist within legislation to facilitate information sharing. Sections 142 to 144 of POCA provide the primary legislative requirements for making disclosures (financial institution or business to government authority). Sections 162 through to 192 of POCA also detail the variety of orders that may be made by a government authority for the purposes of an investigation. These orders include production orders, disclosure orders and customer information orders, and act as mechanisms for information sharing between the authority and financial institution or business subject to the order.
At present, there are no mechanisms in place or under discussion to facilitate information sharing solely between financial institutions or businesses. Section 145 of POCA 2008 details the offence of “tipping off”, so if an institution were to share information with any person or institution other than the relevant government authority, they may, in turn, commit this offence. POCA does provide for a defence to tipping off if there is a common client: this is where an institution makes a disclosure to another institution that relates to a common client or transaction. The disclosure must be for the purpose of preventing an offence, and both institutions must be subject to professional confidentiality.
In 2023, the Isle of Man Financial Crime Partnership was established. This is a public/private partnership, established with the aim of utilising the knowledge and expertise within the private sector to facilitate co-operation and knowledge sharing between industry and the public sector for a collaborative approach.
3.13 Is adequate, current, and accurate information about the beneficial ownership and control of legal entities maintained and available to government authorities? Who is responsible for maintaining the information? Is the information available to assist financial institutions with their anti-money laundering customer due diligence responsibilities as well as to government authorities?
Under the Beneficial Ownership Act 2017, there is a central register of beneficial owners of Isle of Man companies. In 2019, the Crown Dependencies (Guernsey, the Isle of Man and Jersey) made a public commitment concerning Registers of beneficial ownership of companies (the “public commitment”). The judgment of the Court of Justice of the European Union (the “CJEU”) (22 November 2022) impacted considerations in the Crown Dependencies around implementing the public commitment in line with consideration of factors around data protection and human rights. The Crown Dependencies had all committed to provide access to obliged entities for the purpose of conducting customer due diligence by the end of 2022 and had consulted on the position and produced policy positions. However, in light of the CJEU judgment, implementation of this legislation was delayed.
On 13 December 2023, the Crown Dependencies published a joint commitment to increase accessibility and transparency of information held on the beneficial ownership register. Access to information has now been extended to include obligated entities who are required to carry out customer due diligence.
3.14 Is it a requirement that accurate information about originators and beneficiaries be included in payment orders for a funds transfer? Should such information also be included in payment instructions to other financial institutions? Describe any other payment transparency requirements for funds transfers, including any differences depending on role and domestic versus cross-border transactions.
The Island has implemented the EU Directive in relation to wire transfers through orders and regulations. In accordance with the Directive, the ordering financial institution must ensure that all wire transfers carry specified information about the originator (payer), who gives the instruction for the payment to be made, and the payee, who receives the payment. The core requirement is that the payer information consists of name, address, account number, official personal document number, customer identification number or date and place of birth, and that the payee information consists of name and account number. There are also requirements imposed on any intermediary payment service providers. The order includes the ability to apply reduced payer information where the payment service providers of both payer and payee are located within the British Islands. The British Islands are the UK, Guernsey, Jersey and the Isle of Man.
3.15 Is ownership of legal entities in the form of bearer shares permitted?
The Companies (Prohibition of Bearer Shares) Act 2011 provides that bearer shares are not permitted as a form of ownership of legal entities and, under the AML/CFT requirements, the existence of bearer shares in a non-Isle of Man incorporated entity should be considered a risk factor.
3.16 Are there specific anti-money laundering requirements applied to non-financial institution businesses, e.g., currency reporting?
As per question 3.1, there is a wide range of businesses that must comply with the Code. These include DNFBPs, thus there are no other categories of business with additional AML requirements.
3.17 Are there anti-money laundering requirements applicable to certain business sectors, such as persons engaged in international trade or persons in certain geographic areas such as free trade zones?
There is nothing additional required under primary legislation, the Code and associated guidance. It is important, however, to note that the Island implements and enforces sanction regimes. Isle of Man businesses are prohibited from doing business with any entity or individual named on a Sanctions Notice.
3.18 Are there government initiatives or discussions underway regarding how to modernise the current anti-money laundering regime in the interest of making it more risk-based and effective, including by taking advantage of new technology, and lessening the compliance burden on financial institutions and other businesses subject to anti-money laundering controls?
There is an AML/CFT Advisory Group consisting of representatives from the government, the regulatory bodies and industry. This Group regularly discusses matters in relation to developments in the AML/CFT regime, and there have been various discussions within the Group on better acceptance and use of digital identity.
4.1 If not outlined above, what additional anti-money laundering measures are proposed or under consideration?
The FSA is progressing plans to update the way it supervises regulated entities and designated businesses. Internal restructuring has taken place at the financial regulator to implement an enhanced risk-based supervisory framework with effect from 6 April 2023. The Authority retained four supervisory divisions, transitioning from a predominantly sector-based approach to one that places an even greater emphasis on impact and risk.
The new divisions are:
4.2 Are there any significant ways in which the anti-money laundering regime of your country fails to meet the recommendations of the Financial Action Task Force (“FATF”)? What are the impediments to compliance?
In November 2022, MONEYVAL issued its fourth follow-up report on the Isle of Man, following a mutual evaluation report that was adopted in December 2016 which placed the Isle of Man in MONEYVAL’s “enhanced follow-up” procedure. In its previous follow-up report (September 2020), MONEYVAL considered the Isle of Man to comply or mostly comply with 39 out of 40 Financial Action Task Force (“FATF”) recommendations. According to MONEYVAL, the Isle of Man retained moderate deficiencies, implementing just one recommendation – Recommendation 23 – with which the Isle of Man was only “partially compliant”.
4.3 Has your country’s anti-money laundering regime been subject to evaluation by an outside organisation, such as the FATF, regional FATFs, Council of Europe (Moneyval) or IMF? If so, when was the last review?
Please see question 4.2.
4.4 Please provide information on how to obtain relevant anti-money laundering laws, regulations, administrative decrees and guidance from the Internet. Are the materials publicly available in English?
This information is publicly available on the FSA’s website and is in English. The website contains links to both the Code and the Handbook. Primary legislation is available from the Attorney General’s Chambers website and is also in English.
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