Under GFSC’s revised Handbook on Countering Financial Crime and Terrorist Financing (the Handbook), which took effect on 31 March 2019, firms were required to take account of the conclusions of Guernsey’s (yet to be published) National Risk Assessment (NRA) in undertaking their business risk assessments (BRAs) and reviewing their AML/CFT policies, procedures and controls.
Transitional provisions included in the revised regime allowed firms four months from the date of the NRA’s publication – which was previously expected in October – to review their BRAs, and three months thereafter to approve revisions to their policies, procedures and controls.
In light of delays to the publication of the NRA the GFSC announced amendments to the transitional provisions to allow firms to proceed with their reviews of their BRAs and policies, procedures and controls without at this stage taking account of the NRA. Firms will then need to consider the findings of the NRA when their BRAs and policies, procedures and controls next fall due for review.
The GFSC also noted that Guernsey’s Policy and Resources Committee issued additional guidance on terrorist financing risk, which must now be assessed separately from money laundering risk.
Under the GFSC’s proposals:
Simon Walker, Head of Business Advisory says “Given the likely pressures of increased workloads at the start of the calendar year, it is important that regulated businesses take action now to ensure they meet the new deadlines provided by the GFSC. The team here at Aspida is well-placed to guide clients through all aspects of these new requirements.”
If you require assistance with revising BRAs, policy, process and controls – or with any aspect of compliance with the new Handbook – please do not hesitate to contact our expert team, who will be delighted to provide assistance.
Find our more about our Compliance and Risk Management and contact the team here.
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