Handbook on Countering Financial Crime and Terrorist Financing

The Commission has issued in final form, the revised Handbook on Countering Financial Crime and Terrorist Financing (“the Handbook”)

The Commission has made amendments, to the Handbook, in order to take into account the Bailiwick of Guernsey’s National Risk Assessment (“NRA”) on money laundering (“ML”) and the financing of terrorism (“FT”) which was published in January 2020.

In particular the commission has created 2 new appendices;

• Appendix H, mandatory high risk if a client has relevant ties to countries listed in Appendix H, and replaces Part A of the Instructions
• Appendix I, which lists a number of countries and territories that are identified by the UK and US governments, intergovernmental and supranational organisations such as the FATF as presenting certain ML and FT risks. Alongside these sources, information is presented reflecting assessments of a country or territory by non-governmental organisations and think tanks which firms may also find useful when they are determining the level of country risk presented by a business relationship or occasional transaction. The inclusion of a country or territory in Appendix I does not automatically imply that a business relationship or occasional transaction with a relevant connection to a country or territory on Appendix I is high risk, as the firm can continue to take a risk based decision on the level of overall risk within a business relationship or occasional transaction as set out in Section 3.4 of the Handbook.

 As a result Instruction (Number 01/2020) has been repealed as at 19 June 2020.

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