GFSC Handbook Update: Key Changes Unveiled on February 16, 2024
The Guernsey Financial Services Commission (GFSC) published its updated Handbook on 16 February 2024.
Key Changes and Updates
- Proliferation Financing (“PF”) is highlighted and defined.
- The requirement for a suitable and sufficient PF BRA.
- BRAs are to take into consideration the findings of the NRA in respect of the most likely predicate offenses in the Bailiwick.
- Enhancements to the Bailiwck’s sanctions regime including further alignment with international sanctions requirements, with Firms to report on customers, key principals, transactions or assets linked to a sanctioned/designated person and the nature of the business relationship.
- The inclusion of virtual assets and VASPs, with guidance included regarding automated screening testing to be reported to management.
- Maintain a register of all reports to the P&R Committee associated with a sanctioned/designated person in regard to the new rules.
Next steps for firms to consider:
- Undertaking a PF business risk assessment; Establishing the governance process for reporting sanctioned/designated persons made to the Commission.
- Amending SAR procedures to ensure that any red flags linked to PF are included.
Contact our regulatory consulting team to discuss any of the recent changes.
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