Update on revisions to money laundering and terrorist financing business risk assessments and policies, procedures and controls
On 11 October 2019, the GFSC published an Update on Revisions to Money Laundering and Terrorist Financing Business Risk Assessments and Policies, Procedures and Controls.
As a reminder, amendments to the Guernsey AML Handbook took effect on 31 March 2019. Chapter 17 of the Guernsey AML Handbook includes measures for transitioning to the revised requirements as follows:
A requirement to review of the Firm's Business Risk Assessment ("BRA") to ensure it is relevant and up-to-date and considers the conclusions of Guernsey's National Risk Assessment ("NRA").
A requirement for the above review to be undertaken by the later of 4 months from 31 March 2019 and the date of publication of the Guernsey NRA.
A requirement for the Firm to review and update its policies, procedures and controls in line with the amendments to the Guernsey AML Handbook and to have them approved by the Board no later than 3 months from when the BRA is approved.
Updates and amendments have been made to Chapter 17 given the delay in publication of the NRA.
Highlights
Highlights of the update published in mid October are as follows:
- The Policy and Resources Committee has moved the date of publication for the NRA to the end of the year.
- The Policy and Resources Committee will issue guidance on terrorist financing risk shortly for consideration by Firms which will be informed by the NRA findings.
- Firms now have until 29 February 2020 to revise and obtain Board approval for their BRAs.
- Firms have 4 months following the date of approval of the BRA to update and obtain Board approval for any changes made to its policies, procedures and controls in line with the amendments to the Guernsey AML Handbook.
- Firms must consider the NRA’s findings and conclusions when its BRA's and policies, procedures and controls next fall due for review after May 2020.
How can we help you?
Our experienced team can help you to review and update your BRA and to assess the impact of the amendments to your AML Policies and Procedures.
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