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Guernsey [GFSC] Thematic Review on Reporting Suspicion


Today, 15th July 2021, the Commission issued its report on the thematic review on the reporting of suspicion of money laundering or terrorist financing.

The review covered both financial services and prescribed businesses during the second half of 2020.

A copy of the thematic review is here:


All firms that took part in this industry-wide review

  1. Had appointed a money laundering reporting officer ("MLRO") and
  2. Had policies and procedures for reporting suspicion, which provide guidance to their staff on forming suspicion and what to do.
  3. And the vast majority of MLROs interviewed were suitably senior, qualified and independent.


  1. In most firms reviewed, the policies and/or procedures did not cast a complete framework over the reporting process or provide comprehensive guidance for the MLRO and nominated officer on the firm's expectations on the fulfilment of their roles.

  1. Firms should compare their practices and, where there are gaps, introduce updated policies, procedures and controls.

  1. The areas for improvement contained within the report will lead to boards of firms applying greater oversight to the implementation and operation of the policies, procedures and controls for the timely reporting of suspicion,


  1. General insurers and intermediaries are not seen internationally as having a significant vulnerability to money laundering or terrorist financing and therefore are not required to comply with the AML/CFT Handbook.  However, they must report their suspicions to the Financial Intelligence Service ("FIS") and, therefore, are likely to find the findings useful.