Provisions for Enhanced Measures were introduced in 2019 as a consequence of a specific recommendation made by Moneyval in its 2015 report on Guernsey and by the International Monetary Fund in its assessment of Guernsey in 2010.
It is highly likely that the implementation of the Moneyval recommendation by both the GFSC and industry, will be scrutinised by Moneyval during its next evaluation of the Bailiwick in 2024.
The GFSC has observed that while there are firms which understand the requirement to apply enhanced measures, a number are not applying these measures or are not applying measures tailored to specifically address the risk factor(s) presented by the customer.
The letter provides information to firms to assist in their development and maintenance of effective anti-money laundering and countering the financing of terrorism controls.
Practices observed from onsite GFSC inspections include:
We recommend that firms consider the following actions:
Recently, there has been a series of regulatory fines and public statements across Guernsey, Jersey and Malta primarily for shortcomings in respect of Corporate Governance, including the application of timely and effective compliance monitoring and appropriate AML/CFT controls
Our Compliance Associate, Alexander Richards, provides a summary on the importance of Horizon Scanning for organisations