On the 8th and 9th of August 2024, the Guernsey Financial Services Commission delivered a series of presentations in relation to the findings from their thematic review on Governance, Risk, and Compliance Controls for countering Financial Crime. The thematic review was published on the 4th of April 2024, having visited a number of firms within the Estate Agency, Legal and Accountancy Service sectors.
The presentations further emphasised the areas for improvement, highlighting these as follows:
• Effective policies, procedures and controls;
• Oversight of Outsourced Functions;
• Risk Assessments & Identification of the Customer;
• Determination of Business Relationships or Occasional Transactions; and
• Verification of Source of Funds & Source of Wealth.
It was noted that common policy and procedural gaps had been identified, with a particular focus on enhanced measures, the identification and verification of customers, and source of funds & source of wealth.
This shows a continued focus from the commission throughout 2024 in relation to the application of CDD and understanding of client relationships, both across regulated firms and prescribed businesses. As such, it remains key for all firms to ensure that they develop and maintain appropriate policies, procedures and controls, with a particular emphasis on the above noted weaknesses.
Should you need any assistance with compliance matters, please reach out to compliance@aspidagroup.com
