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Guernsey revises AML part of rulebook

Chris Hamblin, Editor, London, 13 November 2019

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The Guernsey Financial Services Commission has issued a revised version of its so-called Handbook on Countering Financial Crime and Terrorist Financing.

The regulator has made its revisions in order to allow firms to "advance work on revising their business risk assessments and policies, procedures and controls to take account of the provisions of Schedule 3 and the rules and guidance in the handbook without delay." The 'handbook' is the GFSC's all-encompassing rulebook.

Having canvassed opinion among financial firms, the regulator has decided that it no longer wants to prescribe individual dates on which this-or-that firm must revise its business risk assessments and policies, procedures and controls. Instead, it is giving all firms one overarching deadline of 31 May 2020 to revise and obtain board approval for their business risk assessments and to update and obtain board approval for their policies, procedures and controls. It does not explain the reason for this change of heart, except with the somewhat tautological statement that it will allow firms to make the necessary changes before the deadline if they like.

The GFSC has also changed rules 17.8 and 17.11 to say that a firm should consider the conclusions of the island's 'National' Risk Assessment the next time it has to review its business risk assessments and policies, procedures and controls. Each firm must do so some time after 31 May 2020 in accordance with the provisions of Paragraphs 3(1) and 3(6) of Schedule 3.

The revisions are effective immediately.

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