GUERNSEY: GFSC Handbook updates evidence ‘proactive approach’ – local expert

Press Release from GFSC, Wednesday 21 February, 2024. 

The Guernsey Financial Services Commission’s (GFSC) updated handbook on Anti-Money Laundering, Countering the Financing of Terrorism, and Countering Proliferation Financing (AML/CFT/CPF) is a proactive move and a sign of things to come, according to Rachel Gardiner, Head of Prescribed Roles at compliance consultancy Newgate Compliance:

“The updated handbook reflects a comprehensive response to the evolving landscape of financial crime, with a specific focus on countering proliferation financing. It is evident that the GFSC is taking a proactive approach to address emerging threats and uphold the highest standards of compliance.

“The fact that the update was introduced after a States of Guernsey consultation shows how the regulator and government in Guernsey are working together to keep the island ahead of the curve and show industry that it’s a compliant and transparent jurisdiction. This is especially important against a backdrop of imminent Financial Action Task Force (FATF) and MONEYVAL assessments for the island.

“Even though we’ve been advised that our risk in Guernsey is very low, we still have to consider the risk that businesses may be exposed to proliferation financing. It’s yet another factor and nuance that businesses need to account for in their risk assessment and update their policies and procedures. The regulator will be expecting to see that businesses have factored it into their three lines of defence and enhanced due diligence training.”

Key updates include modifications to the rules governing pooled bank accounts for local businesses, as well as changes to Chapter 12 of the handbook concerning UN, UK, and Bailiwick sanctions. Additionally, the GFSC made various minor adjustments to enhance the overall efficacy of the framework.

Of notable mention is the incorporation of updated assessments from two sources used in the compilation of Appendix I of the handbook. While there were no alterations to the countries and territories identified in Appendix I, an updated version has been published to reflect the latest information.

Rachel continued: “The GFSC’s commitment to staying ahead of financial crime risks is commendable. The attention to detail, including the incorporation of updated assessments in the handbook, demonstrates a forward-thinking approach that benefits both the financial industry and the broader community.

“We recommend following three lines of defence approach to protect their businesses – firstly, implement robust procedures, policies and training; secondly, comprehensively monitor these; and finally, review and challenge through an independent audit.”