The further draft of the Code published by the Isle of Man Financial Services Authority (IOMFSA) in November is expressed to constitute a “final consultation”. We now can expect the Code to be enacted in materially identical terms and with an effective date of 1 January 2019. Therefore, notwithstanding the time they have bought during consultation, many offshore life companies face a tough timetable to introduce significant changes in their internal governance and customer processes. Those businesses that are not already well advanced in implementing the associated culture change will find that this compounds the challenge.

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