Isle of Man Financial Services Authority

Overview

Outcome Breakdown

Requests by Year

Top Topics

• Finance & Tax (9 requests)
• Financial Services & Regulation (7 requests)
• Transport & Roads (6 requests)
• Policing & Criminal Justice (4 requests)
• Planning & Housing (3 requests)

Notable Cases (15)

[~] FoI Request - Isle of Man Financial Services Authority

2025-10-01 | Some information sent but not all held

A Freedom of Information request was submitted to the Isle of Man Financial Services Authority for five years of monthly statistical data on licensing, enforcement, and internal operations. The Authority responded with partial information, providing specific counts for application statuses and designated business activities, but did not disclose all requested data such as staff numbers or expenditure breakdowns.

• The request covered statistical data from October 2020 to October 2025.
• The Authority's outcome was 'Some information sent but not all held'.
• The response included 13 documents totaling 413 pages.

Data: 2025-10-01, 2025-10-28, 413 pages, 13 documents, 01/10/2020

[-] Further information on Note 18 of the FSA 2024 Accounts

2025-05-20 | Some information sent but part exempt

The request sought confirmation that Note 18 of the FSA 2024 Accounts referred solely to Montpelier (Trust and Corporate) Services Limited and asked for the court appointment date of Grant Thornton Limited. The FSA confirmed the reference was solely to Montpelier but withheld the specific appointment date, citing that the information is already publicly accessible on their website.

• Note 18 of the FSA 2024 Accounts refers solely to liquidation work for Montpelier (Trust and Corporate) Services Limited.
• Grant Thornton Limited was appointed by the Isle of Man Courts to undertake this liquidation work.
• The FSA refused to provide the specific court appointment date in the response letter.

Data: 4674149, 2025-05-20, 2025-05-29, 31st March 2024, Section 20

Exemptions: Section 20 of the Freedom of Information Act 2015 (Information reasonably accessible)

[~] Staff bonuses and performance related pay

2025-02-18 | Some information sent but not all held

The requester asked for details on staff bonus and performance-related pay schemes, including specific payment lists for the last six tax years. The Isle of Man Financial Services Authority confirmed it does not operate a formal bonus scheme but disclosed the existence of a discretionary performance-related incentive for 2023/24, while withholding individual payment data due to privacy exemptions.

• The Authority does not operate a contractual staff bonus or performance-related pay (PRP) scheme.
• A discretionary non-consolidated performance-related incentive (PRI) was introduced in April 2023 for the 2023/24 financial year.
• PRI allocation is decided by a moderation panel comprising the CEO and Senior Steering Group members.

Data: 2025-02-18, 2025-03-14, April 2023, 2023/24, 27 February 2025

Exemptions: Absolutely Exempt Personal Information - s25(b)(i)&(ii)

[-] Settlement Agreements

2024-12-31 | Some information sent but part exempt

The requester asked for the number, reasons, and compensation figures of Settlement Agreements issued by the Isle of Man Financial Services Authority since September 2021, along with a template. The Authority disclosed total monetary settlement amounts by year but withheld specific counts, reasons, and templates due to data protection exemptions regarding personal information.

• The Authority provided total settlement amounts paid between 2021 and 2024.
• Specific breakdowns by reason or individual agreement counts were withheld to prevent identification of individuals.
• No template for Settlement Agreements is held by the Authority as they are created by Manx Industrial Relations.

Data: 2021: £0, 2022: £102,065.90, 2023: £76,902.03, 2024: £0, TOTAL: £178,967.93

Exemptions: Section 25(b)(i) & (ii) of the Freedom of Information Act 2015 (Absolutely exempt personal information); Article 5 of the General Data Protection Regulation (Data Protection Principles); Article 6 of the General Data Protection Regulation (Conditions for lawful processing)

[-] Organisational chart or "Family Tree".

2024-08-08 | Some information sent but part exempt

The requester asked for a detailed organizational chart, staff names, job titles, and salary maxima for the Isle of Man Financial Services Authority, including indirect staff. The Authority provided organizational structures and salary bands but withheld individual staff names and titles for non-key personnel citing personal data exemptions.

• The Authority released an organizational chart showing job grades and current headcount of filled posts.
• Names and job titles for key staff (Members, CEO) were disclosed, but withheld for other staff.
• Salary maxima were provided for six specific job grades ranging from Officer to Head of Division.

Data: 2024-08-08, 2024-08-27, £121,000, £82,000, £63,500

Exemptions: Freedom of Information Act 2015, Section 25 Absolutely exempt personal data

[+] Designated Business civil penalties charged

2022-05-10 | All information sent

The request sought details on civil penalties charged under the Designated Business Act, including amounts, dates, and breached sections. The authority disclosed a breakdown of penalties imposed from 2019 to 2022, noting that most were £5,000 fines for unregistered business activity, with some mitigated or waived due to exceptional circumstances.

• Penalties were primarily imposed under Section 7 of the Designated Businesses (Registration and Oversight) Act 2015 for carrying on business without registration.
• The standard civil penalty amount is £5,000 per contravention.
• Between 2019 and 2022, a total of 12 penalties were recorded, with varying outcomes including full payment, mitigation, waiver, or appeal.

Data: 2019, 2020, 2021, 2022, £5,000

[-] Advocates Disciplinary Tribunals

2022-01-06 | Some information sent but part exempt

The request sought total monetary costs for specific Advocates Disciplinary Tribunal proceedings and a historical range from 2000 to 2021. The Authority disclosed external legal costs for the 2020/07 reference but withheld pre-2011 data due to the temporal scope of the Freedom of Information Act 2015.

• External legal costs for Advocates Disciplinary Tribunal reference 2020/07 were £59,317.96 exclusive of VAT.
• No internal monetary costs were incurred for reference 2020/07 beyond routine overheads.
• The Freedom of Information Act 2015 only applies to information created on or after 11 October 2011.

Data: £59,317.96, 2020/07, 2006-07, September 2000, May 2021

Exemptions: Section 4(1) of the Freedom of Information Act 2015 (temporal scope limitation)

[-] Appointment of Karen Badgerow

2021-10-27 | Some information sent but part exempt

The request sought details on the appointment panel for Karen Badgerow as CEO of the Isle of Man FSA, her links to KPMG Canada, and her referees. The authority disclosed the names of the sub-committee members and the ratification date but withheld information regarding KPMG links and referees under a breach of confidence exemption.

• A UK-based recruitment firm managed the procurement process for the CEO role.
• The recruitment sub-committee comprised Geoff Karran, Alan Smith, Paul Wright, Peter Pell-Hiley, David Stacey, and Lillian Boyle.
• The appointment was ratified by the Board of the newly established Authority on 2 November 2015.

Data: 27 October 2021, 8 November 2021, 2 November 2015, section 26, Financial Services Act 2008

Exemptions: Section 26 of the Act (actionable breach of confidence)

[~] Statistics on Visit Report action points

2020-07-29 | Vexatious request

The requester asked for statistics on red, amber, and blue action points from supervisory visit reports for Trust and Corporate Service Providers from 2011 to 2020. The Isle of Man Financial Services Authority refused the request as vexatious because the data is not centrally collated and the colour-coding system was discontinued in mid-2019.

• The request was refused under section 11(3)(d) of the Freedom of Information Act 2015 as vexatious.
• The requested information is not held in a format that allows extraction without significant effort.
• The colour-coding system for action points (Red, Amber, Blue) ceased to be used in mid-2019.

Data: 2011, 2020, 29 July 2020, 18 August 2020, mid 2019

Exemptions: Section 11(3)(d) of the Freedom of Information Act 2015 (Vexatious request)

[-] Taxpayer funded liquidations of companies linked to Premier Group IoM

2019-09-26 | No information sent - all held but exempt

A request was made for details on taxpayer-funded liquidation costs for companies linked to the Premier Group Isle of Man, but the Financial Services Authority refused to disclose any information.

• The request concerned costs borne by the IoM taxpayer for liquidating Premier Group-linked entities.
• Specific companies mentioned include New Earth Recycling and Renewables, Eco Resources Fund, and their subsidiaries.
• The Isle of Man Financial Services Authority held the information but deemed it exempt from disclosure.

Data: 2019-09-26, 2019-10-21, 979981, Financial Services Act 2008, Schedule 5

Exemptions: Schedule 5 to the Financial Services Act 2008; Information relating to the business or other affairs of any person

[-] Enforcement policy and supervisory approach

2019-04-23 | No information sent - all held but exempt

The applicant requested internal documents detailing the Isle of Man Financial Services Authority's current supervisory approach and enforcement policies produced since March 2018. The Authority refused to disclose the information, citing that the documents are held in draft form pending finalization.

• The request was received on 23 April 2019 and responded to on 16 May 2019.
• The Authority confirmed the information exists but is exempt from disclosure.
• The exemption is based on the information being held in draft form pending finalization.

Data: 2019-04-23, 2019-05-16, 2018-03-29, 2015, 11 pages

Exemptions: Section 41 of the Act (Information held with a view to future publication)

[~] Security and data protection related incidents

2019-03-25 | Not required to fulfill request

The requester asked for a breakdown of security and data protection incidents reported to the Isle of Man Financial Services Authority since 2015, but the Authority refused the request due to the substantial effort required to collate non-centralized data and lack of reporting obligations for certain sectors prior to 2019. However, the Authority voluntarily disclosed that 13 cyber-security incidents were reported in 2018 with no recorded losses.

• The Authority is not required to fulfill the request because compiling the data would involve substantial effort searching individual entity records.
• Reporting requirements for material failures under the Financial Services Act 2008 have existed since 2008, but similar rules for insurers only started in 2019.
• There are no specific reporting requirements for non-material matters or for entities under the Retirement Benefits Schemes Act 2000.

Data: 2019-03-25, 2019-04-12, 2015, 2018, 2008

Exemptions: Substantial compilation or collation of information (not required to do under the Act); Information not held by the Authority

[-] FSA Board Members on the Beneficial Ownership register

2018-07-09 | No information sent - all held but exempt

The requester asked if FSA Chair Lillian Boyle or former Chair Geoff Karran were beneficial owners of RL360 Holding Company Limited. The FSA confirmed neither held reportable investments in the company, though the specific beneficial ownership data was withheld as absolutely exempt under the Beneficial Ownership Act 2017.

• Lillian Boyle (current FSA Chair) does not hold any investment in RL360 Holding Company Limited exceeding the reporting threshold.
• Geoff Karran (former FSA Chair) did not hold any investment in RL360 Holding Company Limited exceeding the reporting threshold at the date of his retirement.
• No closely connected parties of either Boyle or Karran hold such investments in the company.

Data: 522934, 2018-07-09, 2018-07-19, 2018-07-18, £13k

Exemptions: Beneficial Ownership Act 2017 Section 26; Beneficial Ownership Act 2017 Section 27; Freedom of Information Act 2015 Section 27; Data Protection Act 2002; Freedom of Information Act 2015 Section 25(b)(i)

[-] IOMFSA Enforcement Procedures

2018-03-13 | No information sent - all held but exempt

The requester asked for internal IOMFSA enforcement policy documents comparable to the UK FCA's guides, but the authority withheld the information citing a future publication exemption while providing links to existing public overviews and a flowchart.

• The request was received on 13 March 2018 and the response was issued on 29 March 2018.
• The IOMFSA refused to disclose internal documents because they are held with a view to future publication.
• The authority provided a link to a 'Disciplinary Unit Procedure Flowchart' as an alternative resource.

Data: 13 March 2018, 29 March 2018, Section 41, pages 5-6, 369534

Exemptions: Section 41 of the Act (Information held with a view to future publication)

[+] Breaches of AML/CFT Code

2018-03-09 | All information sent

The request sought annual statistics on AML/CFT Code breaches, investigations, prosecutions, and regulatory actions from 2011 to 2017. The Authority disclosed the data in a table, noting that civil penalties are not imposed under the Code itself but referenced a separate penalty under the Financial Services Act 2008.

• The data covers the period from 11 October 2011 to 2017, broken down by calendar year.
• There is no power to impose civil penalties directly under the AML/CFT Code 2015.
• The number of investigated cases includes those referred for prosecution and those subject to regulatory action.

Data: 2011: 0 investigations, 0 prosecutions, 0 civil penalties, 0 regulatory actions, 2012: 1 investigation, 1 prosecution, 0 civil penalties, 0 regulatory actions, 2013: 0 investigations, 0 prosecutions, 0 civil penalties, 0 regulatory actions, 2014: 1 investigation, 0 prosecutions, 0 civil penalties, 3 regulatory actions, 2015: 0 investigations, 0 prosecutions, 0 civil penalties, 0 regulatory actions

Most Cited Exemptions

See Also

• Transparency Scorecard
• Outcome Trends