Regulatory Alerts2020-07-07
Source of Funds and Source of Wealth in Private Wealth Management Thematic Review 2019
The Guernsey Financial Services Commission conducted a thematic review of 47 private wealth management firms to assess their compliance with Source of Wealth and Source of Funds requirements. The review found that while most firms gather initial information, six firms were remediated or referred for enforcement due to failing to apply a risk-based approach to corroborating customer wealth. Regulators emphasized that firms must move beyond accepting customer explanations at face value and instead use independent documentation to verify high-risk relationships, particularly those involving foreign politically exposed persons.
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