If you would like to contribute to this survey, please email Richard East on r.east@trust-world.net
1. How long have trusts been used by private investors, as a vehicle for their asset planning?
2. How are trusts set up and are they registered and open to public scrutiny?
3. Are trusts used for domestic purposes or are they purely for international investors?
4. Can trusts be used to hold the shares in companies registered in the same jurisdiction, especially shares in international business companies or similar zero-taxed vehicles; if so, what are the advantages of doing so?
5. Are there specific advantages of using international trusts to assist in overcoming forced heirship provisions of the jurisdiction of the person that is setting up the trust?
6. What advantages are there in using international trusts as a part of a tax planning regime?
7. What are the particular advantages of using international trusts to protect against creditors?
8. Can trusts be used to protect beneficiaries from their disabilities or extravagance?
9. Can trusts be used to treat income and capital of trust assets in different ways?
10. Can trusts be used to avoid the need to obtain a Grant of Probate on the death of the settlor and in other ways to be used as a substitute for a Will?
11. Is the setting up of a trust and the contents and details of the trust instrument confidential? What limits are there on this confidentiality?
12. What ancillary services are available in a jurisdiction relevant to an international trust operation, such as international banks, trustee services, investment advisers?
13. Is it necessary that a trust set up in the jurisdiction must be managed there or may the trustees comprise individuals or companies situated elsewhere?
14. May the settlor retain the power to decide on the investment of trust assets, the identification of beneficiaries or the allocation of assets to such beneficiaries? What are the consequences of exceeding this?
15. What particular markets are attracted to trusts in the jurisdiction?
16. Who is the person in the jurisdiction with whom the details of the advantages of setting up a trust may be discussed and who should be instructed to set one up?
17. Who is usually engaged to draft the trust instrument; is it a lawyer in that jurisdiction, a standard form from a trust company or similar persons in the country of residence of the settlor, or by a service provider in the jurisdiction?
18. What is the nature of trustees available in the jurisdiction; are they trust companies belonging to banks, associates of law firms, independent trust companies or branches or subsidiaries of international trustee companies?
19. In setting up a trust in the jurisdiction by a foreign settlor, what KYC procedures are required in respect of the settlor, trustees and beneficiaries, and what other anti-money laundering laws are applicable?
20. What is the minimum amount of cash or assets which are recommended to make the expenses of setting up and managing a trust worthwhile?
21. Before an investor elects to set up a trust, he might consider the advantages of alternative arrangements. What advantages are there in these; for example, joint bank accounts, private foundations, insurance or some form of corporate structure or a straightforward power of appointment or an outright gift)?
22. What is the duty of the adviser to ensure that the client understands the nature of the proposed trust and what procedures are adopted generally to ensure that the settlor understands the nature of a trust?
23. What measures are there to combat the abuse of trusts set up to conceal assets, particularly in respect of fraudulent activities or tax evasion by the settlor?
24. Are purpose trusts possible in the jurisdiction and, if so, what are their principal applications?
25. Can creditors attack trust assets directly instead of taking action against the trustees and what measures have been enacted to frustrate action taken by “trust busters”?
26. What procedures are recommended to be followed by trustees to minimise their risk (such as maintaining accurate minutes of meetings and file notes of telephone conversations)?
27. Are professional indemnity insurance policies easily available to trustees and is it the current practice for these to be taken out?
28. What are the obligations on trustees to disclose trust information and to whom would this duty be owed?
29. What is the position relating to trusts engaging in trade or other commercial activities (and is it usual for such activities to be conducted through a company whose shares are held in trust)?
30. What procedures are adopted by banks before setting up a bank account for a trust (references, anti-money laundering procedures etc.,)?
31. Are trustees required to follow any legal provisions relating to the maintenance of trust assets or finance or is the limit to their authority only as may be contained in the trust instrument or by the protector/guardian?
32. Does a trust have to produce annual accounts and, if so, to whom are copies of these accounts routinely supplied?
33. Are there adequate investment advisers and stock exchange and other facilities available for investing trust funds in the jurisdiction where there are liquid assets of the equivalent of $5 million?
34. What reporting requirements are required of trustees in respect of a trust’s financial position which are required to be made to the Regulator, to the settlor or to any other party?
35. Many trusts are now integral parts of more complex arrangements known as ‘Family Offices’. What is the principal use of trusts in such arrangements?
36. What is the status of the jurisdiction in respect of requirements of the OECD on Exchange of Information, the FATF in respect of anti-money laundering laws and the IMF in respect of international banking standards?
37. What are the advantages of the jurisdiction which are marketed to various sectors of the world to encourage their HNWIs to locate their wealth through trusts?
38. Where the trust is discretionary, what procedures should a settlor and beneficiaries expect that the trustees should follow before making a distribution?
39. Where the trust is discretionary and the trustees are not geographically close to the beneficiaries, what procedures are recommended to enable the trustees to have adequate knowledge of the beneficiaries to exercise their discretion properly to fulfil the terms of the trust?
40. Beneficiaries may from time to time approach trustees requesting a distribution in their favour. How are such requests to be handled, bearing in mind the duties of a trustee are to act in a manner fairly between all the beneficiaries where the trust is discretionary?
41. Settlors may contact the trustees requesting that some of “their” trust fund be used in a particular way. How are such demands met?
42. Where a trustee is incompatible with the beneficiaries, may a trustee seek to be relieved of his responsibilities?
43. What rights do beneficiaries have to receive accounts and other information concerning the trust and who else might be included within these rights?
1. Trust Law
(a) What new legislation/regulations and case decisions concerning trusts, or of interest to trustees, have appeared in the last few years?
(b) What new legislation/regulations are expected or are under discussion for introduction in the future?
(c) What is the basis on which trusts are recognised and enforced?
(a) In Re: Poyaidjis 20 February 2004 (unreported), Deemster Kerruish gave a 325 page judgment dealing with a large number of issues and very complex facts. In this High Court case, Deemster Kerruish considered briefly the issue of sham trusts. The Court considered the cases of Abacus (CI) Limited, Trustee of the Esteem Settlement –v- Grupo Torras SA (Royal Court, Jersey 13 June 2003) and Peter Shalson –v- Onofrio Russo (2003) EWHC 1637 and stated:-
“It is purely a question of fact whether a trust is in substance a sham. The sham doctrine is a general one capable of applying to all transactions not just the creation of a trust. Even if one determines that a trust is not a sham, it is again a question of fact as to whether the real trust terms are incorporated in the trust deed or in the letter of wishes.”
The Staff of Government Division (the Island’s Court of Appeal) decision in Rosewood Trust Ltd -v- Schmidt [1999-01] MLR 570, which dealt with the rights of the object of a power of appointment of a discretionary trust to the disclosure of trust documents, was appealed to the Privy Council in London. On 27 March 2003, the Privy Council concluded that:-
(i) the rights of beneficiaries to obtain disclosures from trustees should not be regarded as a proprietary right but as an aspect of the inherent supervising jurisdiction of the court; and
(ii) objects of discretionary and mere powers can apply to the court for an order that the court order the trustees to disclose documents concerning the trust and the court has a discretion whether or not to make such an order.
Further details of the Privy Council decision are available on our website (www.cains.co.im).
Although not a very recent case, it is worth noting the decision in Re: Scottish Life International Assurance Company Limited 19 July 2000 (reported in summary form at [2000] 33 MLB 70). This is a particularly significant decision as it confirms that the remedial constructive trust forms part of Manx law. The concept first found favour with the Manx judiciary in Cusack & Cotter -v- Scroop Limited [1996-98] MLR n-20. However, this case was overturned on appeal ([1997] 29 MLB 42) on the facts and, consequently, the recognition of the remedial constructive trust was merely obiter until Re: Scottish Life International Assurance Company Limited.
(b) On 1 July 2003, the Isle of Man Financial Supervision Commission (the “FSC”) issued a further consultative paper on the licensing of trust service providers (“TSPs”). The FSC has taken the pragmatic step of extending the scope of its consultation process in a bid to strike a balance between the need for regulatory supervision of TSPs and the importance of this sector remaining competitive in a challenging global market place. Best estimates at this stage are that a draft TSP Bill will go through the legislative process in the latter half of 2005.
(c) Generally, the fundamental principles of Isle of Man trust law follow closely those of England & Wales. The Recognition of Trusts Act 1988 applies, with some modifications, the Hague Convention (on the law applicable to trusts and their recognition) to the Isle of Man. Manx courts thereby recognise foreign trusts and seek to uphold the private international law conflicts principle applying to the proper law of the trust, save where to do so would be manifestly incompatible with Isle of Man public policy.
2. Anti-money laundering and anti-terrorist provisions
(a) What is the status of your jurisdiction with the FATF?
(b) What reporting or other requirements are imposed on trustees under anti-money laundering rules when:
(i) accepting appointments to a new trust?
(ii) administering an existing Trust?
(a) The Isle of Man has cooperative status with the FATF and has not at any stage appeared on its list of non-cooperative countries and territories.
(b) The Isle of Man has long had an extensive body of comprehensive anti-money laundering legislation. The Criminal Justice Act 1990 (dealing with all-crimes money laundering), the Drug Trafficking Act 1996 and the Prevention of Terrorism Act 1990 render the laundering of the proceeds of crime illegal and prescribe severe penalties for such offences.
The Anti Money-Laundering Code 1998 imposes mandatory requirements on a wide range of businesses operating in or from the Isle of Man to establish and operate various anti-money laundering procedures (including verification of client identity, record keeping, training of staff and disclosure of knowledge or suspicions of money-laundering activity). The Code applies to the “business of acting as trustee in return for payment or providing or taking steps to provide persons to act as trustee in return for payment”. The obligations and duties under the Code apply not only at the establishment of a relevant business relationship (i.e. the creation of the trust) but also throughout that relationship (i.e. the administration of a trust).
The professional trustee should do ‘know your customer’ checks (“KYC”) on the settlor and any protector or other person with power to influence the choice of trustee or any power to be exercised under the trust. In addition the professional trustee should ensure that all beneficiaries are known to it. Some beneficiaries may not know that they are beneficiaries or the settlor may not want them to know that there is a trust. However, the professional trustee must do full KYC on any beneficiary to whom it is considering making an advance of trust property before it makes the advance. In addition, the professional trustee should do KYC on the source of funds and the source of wealth of the settlor.
3. What measures are there to combat the abuse of trusts to procure the concealment of assets?
(a) Civil concealment from creditors, estranged spouses, tax authorities etc;
(b) Criminal concealment from police, customs, courts etc?
(c) Position with the OECD and their treaty on Exchange of Information and other developments relating to reducing the degree of confidentiality in respect of identity and interests of beneficiaries?
(a) The Fraudulent Assignments Act 1736 (the “1736 Act”) provides that “all fraudulent assignments or transfers of [a person’s assets] shall be void and of no effect against his just creditors”.
In Re: Heginbotham [1999-01] MLR 53, the Isle of Man High Court clarified the provisions of the 1736 Act. It was held that in order to set aside a transfer of assets, there must be an intent on the part of the transferring party to defraud existing creditors. Future unascertained debts are not covered by the Act, although known and ascertained debts which are to fall due on a date in the future are included.
In the context of matrimonial proceedings, a spouse may apply to the Family Division of the High Court under section 27 of the Matrimonial Proceedings Act 2001 to set aside a settlement or trust by the other spouse which was effected with the intention of defeating the applying spouse’s claim for financial relief.
(b) The provisions of the various anti money-laundering legislation may, in some instances, be employed to attack transfers of the proceeds of crime to trusts. For example, under the Drug Trafficking Act 1996, the Isle of Man criminal court has the power, during the sentencing of a drug trafficker, to confiscate the assets of a defendant (provided that they comprise proceeds of drug trafficking). Such power extends to assets which the defendant has transferred at substantially less than their market value to a third party. This power could, therefore, be used to confiscate the assets of a trust set up by the defendant if such assets comprise proceeds of drug trafficking.
(c) As part of its commitment to the OECD, the Island is prepared, on a bilateral basis, to enter into exchange of tax information on request by 2006 with OECD member countries. The OECD published the finalised model Agreement on Exchange of Information on Tax Matters in April 2002, which the Island helped to draft. This model has since been used as the basis for an Exchange of Information Agreement which was concluded between the Isle of Man and the USA in October 2002. Similar Agreements with both Germany and Ireland are at an early stage of negotiation.
The U.S. agreement provides for a bilateral exchange of information based upon a formal request being received by the competent authority in the Isle of Man. A request must be made on an individual case basis and the subject of the request must be under investigation in the requesting jurisdiction. Other safeguards are included to prevent ‘fishing expeditions’. All information exchanged may not be passed on to third parties, and there are strict confidentiality measures in place. The model will have effect from 2004 in respect of criminal tax matters and 2006 with respect to all other tax matters.
4. Asset protection trusts
(a) What measures are there to protect assets in a trust subject to your laws from claims by interested parties by, for example, specific asset protection legislation?
(b) To what extent may asset protection trusts be set aside because of fraud of the settlor?
(c) Does the existence of “fraud” constitute an exception to the rule relating to legal privilege on documents?
The Isle of Man has no specific asset protection legislation. However, to the extent that the assets of a properly constituted trust have passed from the beneficial ownership of the settlor into the legal ownership of the trustees, trusts are, to an extent, automatically asset protective.
The Fraudulent Assignments Act 1736 (the “1736 Act”) provides that “all fraudulent assignments or transfers of [a person’s assets] shall be void and of no effect against his just creditors”. See 3(a) above for further details.
The protection of legal professional privilege does not apply when communications are made for a fraudulent or illegal purpose.
5. Shams
(a) What protection is granted to defeat claims from outside the jurisdiction that a trust is a "sham"?
(b) What are the consequences of an arrangement being found to be a sham in your jurisdiction?
(a) None specifically. If an application is made to the Isle of Man High Court by an interested party to set aside the trust on the ground that it is a “sham”, that application will be heard by the Court and determined according to its merits following common law principles.
(b) The setting-aside of a trust on the ground that it is a sham will normally create a resulting trust in favour of the settlor. This may have significant tax consequences for the settlor. Furthermore, funds which were distributed by the trustees may have to be clawed back.
6. Forced heirship
Are there provisions which protect trusts from forced heirship claims originating from a different jurisdiction, or to what extent are claims recognised?
Section 5 of the Trusts Act 1995 provides that no trust governed by Isle of Man law and no disposition of property to be held by such a trust is:-
“void, voidable, liable to be set aside or defective in any fashion, nor is the capacity of any settlor to be questioned by reason that:-
(a) the law of any foreign jurisdiction prohibits or does not recognise the concept of a trust; or
(b) the trust or disposition avoids or defeats any right, claim or interest conferred by foreign law upon any person by reason of a personal relationship to the settlor or by way of heirship rights or contravenes any rule of foreign law or any foreign judicial or administrative order or action intended to recognise, protect, enforce or give effect to such a right, claim or interest.”
However, the Trusts Act 1995 does not apply to (a) a testamentary trust or disposition unless the trust or disposition is valid under the law of the domicile of the testator at death or (b) a trust or disposition of immovable property unless the trust or disposition is valid under the law of the jurisdiction where the immovable property is situated.
7. Protectors
(a) What specific rules are there relating to protectors: if none, how does general law treat them?
(b) Are protectors regarded as fiduciaries and thereby liable to beneficiaries if care is not exercised?
The trust instrument will normally grant the protector powers in accordance with the settlor’s wishes. It is common for a protector to have power to remove and appoint trustees, change the proper law governing the trust and obtain information regarding the administration of the trust. More extensive powers are sometimes granted, but there is a risk that the protector may be seen to be so involved as to be acting as a de facto trustee.
In Re: Papadimitriou, 18 September 2002 (unreported), the High Court reviewed the law relating to protectors, including the issue of the removal of protectors. Deemster Cain stated that he “was not prepared to say that the Court does not have, in any circumstances, an inherent power to remove a protector, if that were necessary to protect the assets of a trust or to prevent the trusts failing, or if the continuance of a protector would prevent the trusts being properly executed. However … the court would only so act in exceptional circumstances.”
8. Purpose Trusts
(a) Can non-charitable purposes trusts be set up?
(b) What rules govern an enforcer or other persons with responsibility for seeing that trustee comply with the directions in a trust deed setting up a purpose trust?
(c) If purpose trusts are not allowed, are there any particular types of trust which overcome this situation?
(a) The Purpose Trusts Act 1996 permits the establishment of non-charitable purpose trusts provided that the purpose or purposes of the trust are certain, reasonable and possible and are not unlawful, contrary to public policy or immoral. There must be at least two trustees, one of whom must be a “designated person” (essentially a professionally qualified person). The trust deed must appoint a person who is independent of the trustees to enforce the trust (“the enforcer”).
(b) The trust deed must provide for the enforcer to have an absolute right of access to any information or document which relates to the trust, the assets of the trust or the administration of the trust. The High Court may, on the application of the enforcer, make such orders as it considers necessary or expedient to enable or assist an enforcer to enforce a trust or to gain access to any information or document which relates to a trust, the assets of a trust or the administration of a trust.
(c) n/a
9. Tracing of trust assets
Can beneficiaries and others pursue a claim:
(a) When the assets of a trust are mixed with other assets by the trustee; or
(b) When the identity of the trust assets merges with others?
The Isle of Man Courts will generally follow the equitable principles of tracing as laid down by the upper English Courts.
10. Attacking Trusts
(a) Can the creditors attack the trust assets directly instead of taking action against the trustees?
(b) What measures have been enacted to frustrate action by "trustbusters"?
(a) A creditor cannot generally attack trust assets directly. A creditor may be able to do so in a claim based on a constructive or resulting trust: see paragraph 3 above.
(b) None.
11. Foundations
(a) Is a foundation recognised as a separate legal entity, when set up:
(i) In the jurisdiction?
(ii) In another jurisdiction?
(b) How is a foundation treated for tax purposes?
There is no provision in Isle of Man law for the creation of a foundation. Whether or not a foreign foundation would be recognised under Isle of Man law would depend on its validity under the laws of the jurisdiction in which it is incorporated.
12. Conflict
(a) What rules relate to the migration of trusts and changes in the proper law?
(b) Can trusts migrate and change their proper law?
(c) Has the Hague Convention been ratified and have there been any case in which the Hague Convention has featured?
A trust governed by Isle of Man law may be managed and controlled outside the Isle of Man.
Section 3 of the Trusts Act 1995 provides that, if the terms of the trust allow, the governing law may be changed to or from the law of the Island.
The Recognition of Trusts Act 1988 applies, with some modifications, the Hague Convention (on the law applicable to trusts and their recognition) to the Isle of Man. Manx courts thereby recognise foreign trusts and seek to uphold the private international law conflicts principle applying to the proper law of the trust, save where to do so would be manifestly incompatible with Isle of Man public policy.
12. Succession
When a trust inter vivos is used as an alternative to a will what precautions must be observed to prevent the trust deed being regarded as an invalid will and defeating the trust?
The settlor must transfer his entire legal and beneficial ownership of the relevant assets to the trust. If he does not do so, the trust may be considered a bare trust and may be regarded as an invalid will unless it is executed in accordance with the Wills Act 1985. It is important to ensure that a substantive and valid trust is created at the outset.
14. Trustees' powers of investment
(a) Do trustees have complete freedom to invest trust funds at their discretion in the absence of specific instructions in the trust instrument?
(b) To what extent are trust instruments regulated?
The Trustee Acts of 1961 and 2001 govern the law in this area. The Trustee Act 2001 gives the trustee a general power of investment to make any kind of investment that he could make if he were absolutely entitled to the assets of the trust. However, in exercising that power (and investment powers granted specifically by a trust instrument), a trustee must have regard to the standard investment criteria as defined by the Trustee Act 2001. Furthermore, a trustee must obtain and consider proper advice about the way in which, having regard to the standard investment criteria, any power of investment should be exercised, unless he reasonably concludes that in all the circumstances it is unnecessary or inappropriate to do so.
The general power of investment is (a) in addition to powers conferred on trustees otherwise than by the Trustee Act 2001, but (b) subject to any restriction or exclusion imposed by the trust instrument or by any statutory provision.
15. Trading trusts
To prevent trustees incurring personal liability for commercial cases, what precautions should be taken by trustees for trusts which:
(a) Trade directly?
(b) Trade by way of a company where the shares are held by the trustees?
Trustees should ensure that any contracts they enter in to contain an express limited recourse provision limiting their liability under the contract to the value of the trust assets. Where trustees trade by way of a company, of which they are shareholders, they will benefit from limited liability protection according to the usual principles. However, where they are also directors of a company, they will owe direct duties to the company as directors. Furthermore, the trustees may incur personal liability qua directors, for example, if they act in breach of their directors’ duties (which duties could possibly conflict with their fiduciary duties as trustees) or if they are guilty of fraudulent trading.
16. Taxation
(a) Is capital gains tax levied on the settlor when assets are passed to a trustee to be held in trusts?
(b) Is the settlor ever deemed to be taxable on the trust income?
(c) Are beneficiaries ever deemed to be taxable when not actually in receipt of the income?
(d) Is stamp duty or a similar tax imposed when property is passed to a trustee?
(e) What significant developments relating to the use of trusts for tax planning have occurred in the last year
(a) There is no capital gains tax in the Isle of Man
(b) The settlor is not taxable in the Isle of Man on trust income unless he is a trustee or beneficiary and a Manx resident, in which case a charge to income tax could arise.
(c) A charge to Manx income tax may arise on undistributed income where a beneficiary, who is resident in the Isle of Man, has the ability to require such income to be distributed.
(d) Income tax is the only direct form of taxation charged by the Isle of Man. In particular, the Island does not charge death duty, inheritance tax, stamp duty, capital gains tax or capital transfer tax.
(e) No significant developments.
17. Bearer Shares
What is the attitude to Bearer Shares and is there any new legislation affecting them?
The Companies, etc (Amendment) Act 2003 amended the law relating to share warrants (bearer shares) in the Isle of Man with effect from 1 April 2004. Any provision in a company’s memorandum and articles of association permitting the issue of a warrant stating that the bearer is entitled to the shares stated therein shall be void. Any share warrant validly issued before the change in the law shall remain valid in respect of the rights and obligations attached to it. However, in order to exercise any such rights, the holder must first convert the share warrant into a registered share.
18. OECD, FATF and IMF
What is the status of your jurisdiction under the criteria put forward by the OECD, FATF and IMF.
(a) OECD
Commitment agreed. As part of its commitment, the Island is prepared, on a bilateral basis, to enter into exchange of tax information on request by 2006 with OECD member countries. An Exchange of Information Agreement was concluded between the Isle of Man and the USA in October 2002. Similar Agreements with both Germany and Ireland are at an early stage of negotiation.
(b) FATF
The FATF has welcomed the significant progress made by the Island in respect of money laundering legislation and implementation and regards the Island as a co-operative jurisdiction. The FATF Annual Report 2000-2001 stated that, “the Isle of Man has a robust arsenal of legislation, regulations and administrative practices to counter money laundering. Perhaps more importantly, the authorities clearly demonstrate the political will to ensure that their offshore financial institutions and the associated professionals maximise their defences against money laundering, and co-operate effectively in international investigations into criminal funds”. The report added “the standards set in the Isle of Man are close to complete adherence with the FATF’s 40 recommendations”.
(c) IMF
The International Monetary Fund (IMF) is undertaking a review of the regulatory standards in jurisdictions worldwide on a rolling programme basis. The Isle of Man was subject to detailed assessment when a team from the IMF visited the Island in October 2002. This represented the most comprehensive review of the Island’s regulatory and anti-money laundering framework to date, and provided an opportunity to benchmark the Island against published standards. The result of this assessment confirms the Island’s reputation as being amongst the best regulated international financial centres.
The IMF published its report on the Isle of Man on 25 November 2003. The report confirmed that the Isle of Man complies well with international standards and concluded that the Isle of Man had a high level of compliance with international standards in such areas as banking, insurance, securities, anti-money laundering and combating the financing of terrorism. The report commended the proactive approach of the Island’s regulators to achieve high standards in the financial services sector.
19. Counter-terrorism
What measures have been taken to implement the OECD's recommendations of 31st October 2001 to counter terrorists' finances?
The FATF agreed a set of Special Recommendations on Terrorist Financing, which commits members to a range of new standards aimed at denying terrorists, and their supporters, access to the international financial system. All countries were invited by the FATF to undertake a self-assessment exercise measuring their compliance with the Special Recommendations and their commitment to comply with the original 40 recommendations. The Isle of Man Government submitted its response in April 2002, and is confident it demonstrated its strong anti-money laundering position and its ability to comply with the Special Recommendations on Terrorist Financing.
20. Regulation of corporate and trust service providers.
What regulation or control is there over corporate and trust service providers and are there any guidelines issued to these providers?
Corporate service providers must hold a licence (a “CSP licence”) issued by the FSC under the Corporate Service Providers Act 2000 (the “CSP Act”). It is an offence to be engaged in a regulated activity (defined in schedule 1 to the CSP Act) without a CSP licence. Corporate service providers must also comply with the regulatory codes issued by the FSC. See http://www.fsc.gov.im for more details.
