GUERNSEY’S MONEYVAL REPORT … AGAIN
After a very informative seminar last week, I thought I would set out the timetable identified by the FIU, the GFSC and the Policy Council of the work they need to do to implement some of the recommendations of the MoneyVal Evaluation. It also gives an idea when we can expect our workloads to be affected.
- Spring 2016 – Publication of the FIS Annual Report for 2015 (and possibly from previous years as it was last published in 2009)
- May 2016 – Consultation on amendments to the Wire Transfer legislation
- September 2016 – Policy Letter to the Guernsey States of Deliberation to obtain approval for the changes to the primary AML/CFT legislation
- Autumn 2016 – Upon receipt of the IMF model for a National Risk Assessment, Guernsey’s version will be compiled with help from industry in order to comply with the FATF 2012 Recommendations. Recommendation 1 requires Guernsey to identify, assess and understand the money laundering and terrorist financing risks it faces, such an assessment informing a firm’s business risk assessment.
- End of 2016 – Consultation with industry on the changes to the Handbooks for Financial Services Businesses and Prescribed Businesses
- End of 2016 – Completion of the review of Guernsey Terrorist Financing legislation
- 2016 or 2017 – Approval of the amendments to the Sanctions legislation to close the gap between UN designations and the EU designations
- January or Easter 2017 – Approval of Sark Chief Pleas of amendments to primary legislation
- September 2017 – Progress Report to MoneyVal
Richard Walker, the Director of Financial Crime and Regulatory Policy of the Policy Council, continued the list with the following work streams:
- consideration of the inclusion of manumitted organisations on the Register of Non Profit Organisations but taking into account the treatment of trusts with long stop charitable beneficiaries
- discussions with GAT to follow up on the recommendation of both the IMF and MoneyVal to include the requirement for non-professional trustees to maintain information on beneficial ownership
- review of corruption and confiscation legislation.
A long list – good luck!