2017-11-15
The Guernsey Financial Services Commission published this 2017 thematic review to assess and improve financial crime governance, risk management, and compliance frameworks for fund managers and administrators. The assessment revealed a critical disconnect between firms' identified financial crime exposures and their actual mitigation controls, largely driven by generic, outsourced compliance programmes and inconsistent board oversight. Firms are required to adopt proportionate, risk-based compliance monitoring, establish clear risk appetites, conduct regular board reviews, and ensure targeted staff training and system testing directly address their specific business vulnerabilities.