GFSC consults on Guernsey AML handbook and proceeds-of-crime law

The GFSC and Guernsey’s Policy & Resources Committee are consulting on changes to the AML/CFT/CPF Handbook and proceeds-of-crime law.

The proposals respond to recommended actions in MONEYVAL’s evaluation report, published in early 2025, concerning Guernsey’s supervisory framework. The consultation is a policy and legislative process, not an enforcement action.

The proposed statutory amendments target Schedule 3 to the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999. The consultation also proposes minor changes to Schedules 1 and 4 of the law, addressing two unintended consequences of the Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022.

The affected licensee cohort includes firms subject to the Handbook, including banks, fiduciaries, fund administrators, investment businesses, insurers and other regulated firms. The source does not specify which Handbook provisions will change in each sector, so firms will need to review the draft text rather than infer scope from the MONEYVAL reference.

The consultation also asks for views on Appendix C of the Handbook, which lists jurisdictions with standards considered equivalent to Financial Action Task Force requirements. The list supports introducer arrangements and intermediary provisions, making the review relevant to customer due diligence, beneficial-ownership checks and third-party reliance in trust-company and fund structures.

For Guernsey firms, the practical work will involve legal mapping and control documentation. Firms will need to compare the draft Handbook with existing AML/CFT/CPF policies, review reliance arrangements linked to Appendix C and assess whether changes to proceeds-of-crime law affect onboarding, escalation or record-keeping procedures. The GFSC has not provided a compliance cost, headcount expectation, consultation deadline or commencement timetable in the announcement.

The Commission’s statement, issued jointly with the Policy & Resources Committee, said the proposals address MONEYVAL’s recommended actions concerning the supervisory framework. It directs firms and other respondents to the consultation paper, draft legislation and draft Handbook changes on the GFSC Engagement Hub.

The next step is publication of the consultation deadline and final instruments. Firms should track the GFSC Engagement Hub, contact the Commission’s Financial Crime policy team and monitor the Policy & Resources Committee for the legislative timetable.