I haven’t written a blog on this site for a while but feel compelled to do so with regard to the latest delay in the publication of Guernsey’s National Risk Assessment (NRA).
Firstly, I should say that I am not involved as a politician with the NRA although, as most of you know, I was deeply involved in the scrutiny of the legislation introducing the new AML/CFT regime. One aspect of that was my suggestion that, as the NRA should be taken into account as part of a firm’s review of its business risk assessment (BRA) and, therefore, its procedures, the clock for the production of the BRA and procedures should not start ticking until after the NRA has been issued.
So we hear this week that the NRA has been delayed until the end of June 2019. This is, of course, most disappointing and the reasons for this delay are yet unknown. However, why have we had to hear about this through the grapevine? Why has there not been a public notification of its delay? Again, the decision was to notify industry bodies and they notify their members – yet why should those who are not members of such bodies have to hear it second hand? Needless to say, I have made it clear that this should have been announced by the GFSC on their website or on gov.gg.
That said, I thought I would, therefore, let you know what I have heard. So far, this means that the BRA needs to be approved by the Board by the end of October 2019 and procedures rolled out by the end of January 2020. We are also advised that firms are strongly encouraged to update procedures which are not dependent on the NRA such as PEPs and the changes made to beneficial ownership.
Hope that helps!