Regulatory Alerts2024-03-15
AML/CFT/CPF Guidance for Unregistered 'Upto6' Directors
The Guernsey Financial Services Commission issues this guidance to clarify the reduced anti-money laundering, counter-terrorist financing, and counter-proliferation financing obligations for unregistered directors using the 'up-to-6' licensing exemption. The document mandates specific customer due diligence procedures, including the identification and verification of the company, authorized representatives, and beneficial owners, while permitting reliance on licensed administrators under strict conditions. It further requires enhanced due diligence measures for high-risk relationships involving foreign politically exposed persons or connections to designated high-risk jurisdictions.
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