Regulatory Alerts2025-05-15
Consultation on Guidance for Custodians of Open-Ended Collective Investment Schemes with Indirectly Held Assets
The Guernsey Financial Services Commission issued a consultation paper seeking feedback on proposed guidance for Designated Custodians of Open-Ended Collective Investment Schemes holding assets indirectly. The draft guidance requires custodians to adopt a risk-based approach to 'look through' holding structures to verify ultimate ownership and mitigate money laundering risks. It outlines expectations for ongoing monitoring, documentation, and ownership verification while noting exceptions for regulated custodians and operating companies.
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