MoneyVal – Something For Everyone



MoneyVal have finally issued the 4th Round Evaluation of Guernsey and, whilst everyone pats themselves on the back (and why not – Guernsey has done very well) there is still some aspects of concern for all licensees, the regulator and the FIU.
The headlines below could be the future…..

If you’re bad, you’ll pay more … if your suspicious and don’t report, you will be punished … no more simplified or reduced CDD for many low risk relationships … EDD compulsory for many more FSB relationships … lawyers and accountants no longer Appendix C businesses … independent audit functions needed to test compliance ….

But then the good news for FSBs …..

  • Will trusts need to have a Guernsey registered agent or TCSP trustee?
  • Will TCSPs be needed for all Guernsey companies?
  • The AGCC should provide additional guidance particularly CDD measures.
  • The FIU should provide more information in public reports.

This is just my view of the Summary and, as we know, the devil is in the detail. But I am sure we have the time to read the 322 page report whilst we wait with interest to see what the GFSC will do – looking forward to the 11th February and their Industry Presentation on the Moneyval Report Feedback.

Welcome to a new approach to AML/CFT


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