minutes of internal working groups

Summary

The requester sought minutes from the AML/CFT Technical Group and Financial Crime Strategic Board for 2020-2024 to analyze regulatory gaps and corporate governance assurances. The Cabinet Office determined it was not required to fulfill the request due to the applicant's failure to provide necessary clarifications regarding specific topics and organizations despite multiple attempts.

Key Facts

• The request was received on 2024-12-12 and the outcome was issued on 2025-01-16.
• The authority requested clarification on date ranges, specific discussion points, and relevant international organizations.
• The requester stated they wanted 'any and all unpublished minutes' without filtering or interpretation.
• The requester admitted they had not yet finalized which international organizations were relevant to the request.
• The final outcome was 'Not required to fulfill request' due to the lack of sufficient clarity to locate the information.

Data Disclosed

• 2024-12-12
• 2025-01-16
• 2020
• 2024
• 20
• 40
• 20th December 2024
• 15 January 2025
• 4315617

Exemptions Cited

• Request not required to be fulfilled due to lack of clarity and insufficient information to identify the records

Original Request

minutes of the AML/CFT Technical Group and the Financial Crime Strategic Board as per the AML/CFT Advisory Group to clarify discussion points to corroborate any specific assurances that specific matters would be discussed in the relevant working group and in line with the UK and international organisation expectations of corporate governanc We wrote to ask you for further clarification: In order to identify and locate the information that you have asked for we need some further information from you and ask you for clarification. In particular, it would be helpful to know: minutes of the AML/CFT Technical Group and the Financial Crime Strategic Board * Please can you confirm the date range for this request? as per the AML/CFT Advisory Group to clarify discussion points * Please can you confirm the specific topics or discussion points that you are asking us to search for? to corroborate any specific assurances that specific matters * Please can you advise which specific matters they are referring to? would be discussed in the relevant working group * Please can you advise which working group you are referring to? and in line with the UK and international organisation expectations * Please can you specify which UK and international organisations you are referring to? of corporate governance You provided the following response: I would like the same date range as the AML CFT Advisory Group minutes. All information in any matching minutes from 2020 to 2024 to analyse and better understand the scope, any roadmap, any timelines and any benchmarked gaps in the regulatory framework that could result in the Isle of Man with blacklist status or with greylist status. If there are 20 or 40 PDF documents in the same network directory or directories then I would like an email or emails with unfiltered attachments and any minimised redactions to be a far faster process than trying to manually filter specific matters. The Chief Minister assured every voter and every taxpayer that corporate governance issues (something that clearly includes domestic public sector corruption) would be identified and would be remedied as a lesson learned from the Dr Ranson scandal. I have not yet finalised and prioritised the most relevant international organisations. On 20th December 2024 we wrote to you asking you to further clarify as follows: Could you please further clarify what you mean by: 'the scope, any roadmap, any timelines and any benchmarked gaps in the regulatory framework' Could you also clarify if you are referring to any particular organisations? 'blacklist status or … greylist status'? - noting you have responded to previous requests for clarity in this regard with 'I have not yet finalised and prioritised the most relevant international organisations'. Please confirm so that we can assist you and search for what you are looking for. You provided the following response: I am confused. I have clarified that I want any and all unpublished minutes from the 2 other AML CFT working groups in the same timeline as the published minutes from the 1 AML CTF working group (2020-2024). I do not need any help to filter in or out any information or any interpretation as I will review the raw information in the raw minutes and identify the information that I require. I have been t

Data Tables (1)

Full Response Text

1

Government Office Douglas Isle of Man IM1 3PN Telephone: (+44) 01624 686244
Website: www.gov.im/co

Our ref: 4315617 15 January 2025

Dear ###

We write further to your request received 12 December 2024, which states:

"Minutes of the AML/CFT Technical Group and the Financial Crime Strategic Board as per the AML/CFT Advisory Group to clarify discussion points to corroborate any specific assurances that specific matters would be discussed in the relevant working group and in line with the UK and international organisation expectations of corporate governance”

On 20 December 2024, we wrote to ask you for further clarification. We asked:

• “Minutes of the AML/CFT Technical Group and the Financial Crime Strategic Board…” Please can you confirm the date range for this request? • “…as per the AML/CFT Advisory Group to clarify discussion points…” Please can you confirm the specific topics or discussion points that you are asking us to search for? • “…to corroborate any specific assurances that specific matters…” Can you advise which specific matters you are referring to? • “…would be discussed in the relevant working group…” Please can you advise which working group you are referring to? • “…and in line with the UK and international organisation expectations of corporate governance” • Please can you specify which UK and international organisations you are referring to?

You provided the following response:

“I would like the same date range as the AML CFT Advisory Group minutes. All information in any matching minutes from 2020 to 2024 to analyse and better understand the scope, any roadmap, any timelines and any benchmarked gaps in the regulatory framework that could result in the Isle of Man with blacklist status or with greylist status.

If there are 20 or 40 PDF documents in the same network directory or directories then I would like an email or emails with unfiltered 2 attachments and any minimised redactions to be a far faster process than trying to manually filter specific matters.

The Chief Minister assured every voter and every taxpayer that corporate governance issues (something that clearly includes domestic public sector corruption) would be identified and would be remedied as a lesson learned from the Dr Ranson scandal.

I have not yet finalised and prioritised the most relevant international organisations.”

On 20th December 2024 we wrote to you asking you to further clarify as follows:

• Could you please further clarify what you mean by “the scope, any roadmap, any timelines and any benchmarked gaps in the regulatory framework” • Could you also clarify if you are referring to any particular organisations regarding “blacklist status or with greylist status'? – We note that you have responded to previous requests for clarity in this regard with “I have not yet finalised and prioritised the most relevant international organisations.“ • Please confirm so that we can assist you and search for what you are looking for.

You provided the following response:

“I am confused.

I have clarified that I want any and all unpublished minutes from the 2 other AML CFT working groups in the same timeline as the published minutes from the 1 AML CTF working group (2020-2024).

I do not need any help to filter in or out any information or any interpretation as I will review the raw information in the raw minutes and identify the information that I require.”

Unfortunately, after having been asked for clarification on your request twice, you have not provided an adequate description of what information you wish to be searched for and it is unclear what specific recorded information you are requesting.

Therefore we are unable to proceed further with your request at this time and Cabinet Office is issuing a practical refusal to your request under Section 11(3)(c) of the Freedom of Information Act 2015 (the Act) as you have submitted at request that does not comply with Section 9 of the Act. Section 9(5)(a)(iii) of the Act states that the applicant is required to provide an adequate description of the information requested. As you have not provided an adequate description of the information, Cabinet Office is not obliged to comply with your request.

However, to provide you with advice and assistance, we invite you to note that there is a large amount of publicly available information in respect of the Isle of Man’s 3 commitment to countering financial crime. This information includes the anti-bribery and corruption website and strategy, financial crime strategy, minutes of meetings with the AML Advisory Group (a forum for public sector and professional bodies to share information and facilitate cooperation in order to combat the misuse of the Isle of Man's financial systems by persons attempting to commit financial crimes), risk assessments, MONEYVAL reports, sanctions guidance and beneficial ownership.

The Cabinet Office, in collaboration with other agencies, also delivers outreach and engagement sessions on all aspects of financial crime and the Isle of Man’s compliance with international standards. These outreach sessions are scheduled with the relevant professional bodies and are also available on request.
For convenience, all publicly available information can be accessed via this web page: https://www.gov.im/categories/business-and-industries/anti-money-laundering-and- countering-the-financing-of-terrorism-amlcft/ Should you wish to submit a fresh request in simplified terms please complete and submit the required form available on our website at www.gov.im/about-the- government/freedom-of-information/make-a-freedom-of-information-request/.

Please quote the reference number 4315617 in any future communications.

Your right to request a review

If you are unhappy with this response to your freedom of information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically or by delivery/post.

An electronic version of our complaint form can be found by going to our website at https://services.gov.im/freedom-of-information/Review . If you would like a paper version of our complaint form to be sent to you by post, please contact me and I will be happy to arrange for this. Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded.

If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on; 1. Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act 2015; or 2. Whether we are justified in refusing to give you the information requested.
In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision. More detailed information on your right to a review can be found on the Information Commissioner’s website at www.inforights.im. 4 Should you have any queries concerning this letter, please do not hesitate to contact me. Further information about freedom of information requests can be found at www.gov.im/foi.

I will now close your request as of this date.