Print Article

GFSC Director Registration Regime update 6/9/2023


Further to the launch of a director registration regime for individuals holding certain categories of directorships, the GFSC wishes to remind individuals who qualify for registration that they have until 1 October 2023 to register.

Amendments made to the Criminal Justice (Proceeds of Crime) Law, 1999 and an amendment to the Regulations of Fiduciaries, Administration Businesses and Company Directors, etc. (Bailiwick of Guernsey) Law, 2020 Law established a registration regime for individuals who use the “up to six directorships” exemption from fiduciary licensing where no other exemption from registration applies.

By way of background, individuals who currently use the “up to six directorships” exemption in the Fiduciaries Law are required to comply with the AMLCFT measures in Schedule 3 to the Proceeds of Crime Law, but they are not supervised.

Under this registration regime, there is a reduced set of AML/CFT obligations for them to comply with. The registration regime enables the GFSC to supervise their compliance with these requirements.

The development of this regime has considered feedback from public consultations issued late, last year.

It affects Bailiwick residents who use the

  • Exemption in the Fiduciaries Law, [which allows them to hold directorships of SIX OR FEWER COMPANIES which do not fall under any other exemptions from licensing in the Fiduciaries Law] or
  • Exemptions from registration in Schedule 5 to the Proceeds of Crime Law.

This means that the director registration regime will not directly impact individuals who rely on other exemptions under the Fiduciaries Law, including.

  • Unrewarded directors (such as recreational or charitable directorships),
  • Directors of companies based in Guernsey which are trading locally (such as local florists, grocers, restaurants),
  • Employees/officers of licensed trust and corporate service providers holding directorships in the course of their duties (such as licensed company administrators, fund administrators),
  • Directors of supervised bodies (such as authorised/licensed collective investment schemes, insurers and insurance managers) and
  • Directors of prescribed businesses (such as estate agents and law and accountancy firms).

Details on the regime, which explain.

  • Who should register,
  • The application process for registering and
  • The regulatory obligations upon them,

Are available through the Director Registration Regime page.

The Commission has been hosting workshops on the registration regime, the last of which is scheduled for Friday 15 September 2023 from 9.00am. These workshops cover information on the types of directorships which qualify, how to register and an explanation of the AMLCFT obligations which apply to registered directors.

Those wishing to attend the 15 September workshop at the Commission’s offices are invited to contact the GFSC at to book a place.



The Team

Meet the team of industry experts behind Comsure

Find out more

Latest News

Keep up to date with the very latest news from Comsure

Find out more


View our latest imagery from our news and work

Find out more


Think we can help you and your business? Chat to us today

Get In Touch

News Disclaimer

As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email