Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF)

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 1 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 1 March 2019 Revised Handbook on Countering Financial Crime and Terrorist Financing released in final form Announcement: https://www.gfsc.gg/news/handbook-countering-financial-crime-and-terrorist-financing-0

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 2 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 13 June 2019 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/article/handbook-countering-financial-crime-and-terrorist-financing-1 Summary of changes Paragraphs affected • Introduction of an activation date of 31 March 2019 for the application of measures relating to domestic politically exposed persons (“domestic PEPs”). • Amendments to the legal definitions of Money Laundering Compliance Officer (“MLCO”) and Money Laundering Reporting Officer (“MLRO”). • Amendments to rules and guidance on collective investment schemes traded on a recognised stock exchange. • Amendments to guidance on employer funded benefit and pension schemes. • Other typographical and grammatical corrections Chapter 2 2.1, 2.27, 2.56, 2.58, 2.60, 2.61, 2.63, 2.65, 2.68, 2.70 Chapter 3 3.24, 3.35 Chapter 4 4.68, 4.70, 4.73, 4.75 (prev. 4.74), 4.76 (prev. 4.75), 4.77, 4.78, 4.79 Chapter 7 7.97, 7.146 Chapter 8 8.40, 8.41 (prev. 8.40), 8.60 (prev. 8.59) Appendix A MLCO definition, MLRO definition, PEP definition

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 3 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 1 November 2019 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/article/handbook-countering-financial-crime-and-terrorist-financing-2 Summary of changes Paragraphs affected • Amendments to provide firms with one overarching deadline of 31 May 2020 to revise and obtain Board approval of their business risk assessments and to update and obtain Board approval of their policies, procedures and controls. • Amendments to clarify that a firm should consider the conclusions of the National Risk Assessment when its business risk assessments and policies, procedures and controls next fall due for review after 31 May 2020. Chapter 17 17.7, 17.8, 17.11

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 4 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 29 November 2019 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/article/iceland Summary of changes Paragraphs affected • Removal of Iceland from Appendix C following the Financial Action Task Force’s recent public statement identifying strategic deficiencies in Iceland’s regime for tackling money laundering and terrorist financing. Appendix C Iceland - removed

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 5 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 29 April 2020 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/article/handbook-countering-financial-crime-and-terrorist-financing-3 Summary of changes Paragraphs affected • Transitional provisions timeframes relating to the approval of business risk assessments and policies and procedures pushed back from 31 May 2020 to 30 September 2020. • Transitional provisions timeframe relating to the review of existing high-risk customers pushed back from 31 December 2020 to 31 December 2021 (deadline for non-high risk reviews remains at 31 December 2021). Chapter 17 17.8, 17.11, 17.26, 17.27

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 6 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 19 June 2020 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/article/handbook-countering-financial-crime-and-terrorist-financing-4 Summary of changes Paragraphs affected • Removal of references to Business from Sensitive Sources Notices. • Addition of Appendix H, which lists those countries and territories which the Financial Action Task Force (“FATF”) has identified with significant strategic deficiencies in their regimes to counter ML, FT and financing of proliferation for which it has called for the application of countermeasures. • Addition of Appendix I, which lists a number of countries and territories that are identified by the UK and US governments, intergovernmental and supranational organisations such as the FATF as presenting certain ML and FT risks. Alongside these sources, information is presented reflecting assessments of a country or territory by non-governmental organisations and think tanks. • Amendments to rules and guidance regarding firms taking into account the Bailiwick of Guernsey’s National Risk Assessment (“NRA”) on ML and FT. • Amendments to guidance in respect of firms considering country or geographical area risk factors and identifying high risk countries and territories for both ML and FT purposes. • Reintroduction of the offering of insurance products to another regulated FSB by a Guernsey licensed insurer to the list of qualifying products and services captured under the intermediary provisions. • Other typographical and grammatical corrections. Chapter 1 1.31, 1.32 Chapter 2 2.50 Chapter 3 3.39 (prev. 3.38), 3.40 (prev. 3.39), 3.43 (prev. 3.42), 3.50 (prev. 3.49), 3.52, 3.77, 3.78, 3.79, 3.81 (prev. 3.76), 3.89 (prev. 3.84), 3.93, 3.98 (prev. 3.92), 3.99 (prev. 3.93), 3.100 (prev. 3.94), 3.101, 3.104 (prev. 3.97), 3.105 (prev. 3.98) Chapter 8 8.23, 8.24, 8.95, 8.96, 8.96 (prev. 8.97), 8.98 Chapter 9 9.32, 9.53, 9.71, 9.72 Chapters 10-13 10.13, 11.20, 13.66 Appendix C – Jurisdiction assessment links Bermuda, Bulgaria, Cyprus, Estonia, Hungary, Isle of Man, Jersey, Latvia, Liechtenstein, Lithuania, Malta, Slovenia

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 7 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 30 October 2020 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/article/handbook-countering-financial-crime-and-terrorist-financing-5 Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1) • Appendix I – updated countries/territories listed in United States Department of State: Trafficking in Persons Report (Source 5) • Appendix I – updated countries/territories listed in United States Department of the Treasury: Terrorist Assets Report and the United States Department of State: Country Reports on Terrorism (Source 6) • Appendix I – updated countries/territories from the US think-tank: Fund for Peace / Foreign Policy magazine: Fragile States Index (Source 10) • Appendix I – updated countries/territories from the Global Terrorism Index (Source 11) • Other typographical and grammatical corrections. Chapter 1 1.28, 1.32 Chapter 3 3.78, 3.79, 3.93, 3.104, 3.105 Chapter 8 8.23, 8.43, 8.95 Chapter 12 12.6, 12.7 Appendix I – Country/territory changes Added to Appendix I: North Sinai Source entries amended: Afghanistan, Algeria, Burkina Faso, DR Congo, Congo Republic, Cuba, Egypt, Guinea, Gambia, Lebanon, Lesotho, Mauritania, Mongolia, Nicaragua Removed from Appendix I: Bhutan, Iceland, Saudi Arabia Appendix I – Relevant and External Sources links Source 1, Source 5, Source 6, Source 10 – links updated

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 8 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 15 February 2021 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/handbook-countering-financial-crime-and-terrorist-financing-7 Summary of changes Paragraphs affected • Amendments to reflect the new mechanism for the implementation of UN and UK sanctions in Guernsey following Brexit. • Amendments to guidance regarding the requirement to regularly review any relationship risk assessment and the extent to which a business relationship is monitored. • Amendments to rules and guidance regarding identifying beneficiaries when establishing a trust or entering into a business relationship or occasional transaction with a trust. • Amendments to rules and guidance regarding understanding the ownership and control structure and to identify and take reasonable measures to verify the identity of beneficial owners when undertaking customer due diligence on a customer which is a trust. • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1) Chapters 1-3 1.8, 2.16, 3.17, 3.89, 3.106 (prev. 3.105) Chapter 7 7.93, 7.96, 7.98 (prev. 7.97), 7.99 (prev. 7.98), 7.100, 7.101 (prev. 7.99), 7.102 (prev 7.100), 7.104, 7.105 (prev. 7.102), 7.109 (prev. 7.106), 7.111 (prev. 7.108), 7.115, 7.116, 7.117, 7.118, 7.147 (prev. 7.140), 7.148 (prev. 7.141), 7.152 (prev. 7.145) Chapters 11-15 11.29, Chapter 12 title, 12.2, 12.3, 12.4, 12.6, 12.10 (prev 12.9), 12.11 (prev 12.10), 12.18 (prev 12.17), 12.18, 12.20, 12.21, 12.22, 12.23, 12.25, 12.31, 15.30 Appendix A (Glossary of Terms) The Relevant Enactments, The Restrictive Ordinances Appendix B (References) Afghanistan (Restrictive Measures) Ordinances, 2011 Al-Qaida (Restrictive Measures) Ordinances, 2013 The Sanctions (Bailiwick of Guernsey) Law, 2018 Appendix I – Country/territory changes Removed from Appendix I: The Bahamas (notified 12 Jan 2021)

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 9 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 5 March 2021 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/country-lists-updates-handbook-and-instruction Summary of changes Paragraphs affected • Removal of Cayman Islands from Appendix C following the Financial Action Task Force’s recent public statement. • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1) • Appendix I – updated countries/territories listed by the OECD as jurisdictions that have yet to implement agreed tax standards (Source 2) • Appendix I – updated countries/territories from the Worldwide Governance Indicators project (Source 4) • Appendix I – updated countries/territories listed in United States Department of the Treasury: Terrorist Assets Report and the United States Department of State: Country Reports on Terrorism (Source 6) • Appendix I – updated countries/territories from the TRACE Bribery Risk Matrix (Source 8) • Appendix I – updated countries/territories from the Transparency International: corruption perceptions index (Source 9) • Appendix I – updated countries/territories from the Global Terrorism Index (Source 11) Appendix C – Country/territory changes Removed from Appendix C: Cayman Islands Appendix I – Country/territory changes Added to Appendix I: Cayman Islands, Senegal Source entries amended: Azerbaijan, Belarus, Belize, Benin, Bosnia and Herzegovina, Burkina Faso, China, Colombia, Dominican Republic, Ecuador, El Salvador, Gabon, Gambia, Guyana, Kenya, Kyrgyz Republic (Kyrgyzstan), Lesotho, Malawi, Mexico, Moldova, Morocco, Mozambique, Nepal, Paraguay, Philippines, Russia, South Sudan, Sri Lanka, Tanzania, Timor￾Leste (East Timor), Trinidad & Tobago, Turkey, Ukraine, Removed from Appendix I: Aruba, Brunei, Kazakhstan, Kuwait, Maldives, Mongolia, Sao Tome and Principe, Solomon Islands, Suriname, Thailand Appendix I – Relevant and External Sources links Source 1, Source 2, Source 4, Source 6, Source 8, Source 9, Source 11 – reports/links updated

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 10 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 5 July 2021 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/updates-handbook-countering-financial-crime-and-terrorist-financing-and-issuance-instruction Summary of changes Paragraphs affected • Amendment to rules and guidance on collective investment schemes traded on a recognised stock exchange. • Update to hyperlinks • Removal of Malta from Appendix C following the Financial Actions Task Force’s recent public statement. • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1) Chapter 4 4.71, 4.74, 4.75, 4.76 Chapter 1 1.8 Chapter 12 12.10 Appendix B The Relevant Enactments, Other Relevant Legislation, Other Official Websites Appendix C – Country/territory changes Removed from Appendix C: Malta Appendix I – Country/territory changes Added to Appendix I: Malta Source entries amended: Haiti, Philippines, South Sudan Removed from Appendix I: Ghana Appendix I – Relevant and External Sources links Source 1 - link updated

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 11 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 5 November 2021 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/amlcft-handbook-appendix-i-update-0 Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1) Appendix I – Country/territory changes Added to Appendix I: Jordan Source entries amended: Mali and Turkey Removed from Appendix I: Botswana and Mauritius Appendix I – Relevant and External Sources links Source 1 - link updated

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 12 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 22 March 2022 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/amlcft-handbook-appendix-i-update-1 Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1) Appendix I – Country/territory changes Added to Appendix I: United Arab Emirates Source entries amended: Zimbabwe Appendix I – Relevant and External Sources links Source 1 - link updated

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 13 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 21 July 2022 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/amlcft-handbook-update-and-gibraltar-instruction Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1) Appendix C – Country/territory changes Removed from Appendix C: Gibraltar Appendix I – Country/territory changes Added to Appendix I: Gibraltar Removed from Appendix I: Malta Appendix I – Relevant and External Sources links Source 1 - link updated

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 14 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 16 November 2022 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/amlcft-handbook-update Summary of changes Paragraphs affected • Chapter 4 – amendments to guidance regarding liquidators registered with the Commission acting as the nominated firm responsible for investor CDD of suspended collective investment schemes authorised/registered with the Commission • Appendix H – updated countries/territories listed as FATF jurisdictions subject to a call for action • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1) Chapter 4 4.57, 4.65 Appendix H – Country/territory changes Added to Appendix H: Myanmar (Burma) Appendix I – Country/territory changes Removed from Appendix I: Myanmar (Burma) – moved to Appendix H Source entries amended: Congo Democratic Republic of, Mozambique, Nicaragua, Pakistan, Tanzania Appendix I – Relevant and External Sources links Source 1 – link updated

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 15 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 13 March 2023 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/country-lists-updates-handbook-and-instruction-0 Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1) Appendix C – Country/territory changes Removed from Appendix C: South Africa Appendix I – Country/territory changes Added to Appendix I: South Africa Appendix I – Relevant and External Sources links Source 1 - link updated

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 16 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 10 July 2023 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/updates-amlcft-handbook Summary of changes Paragraphs affected • Chapter 2 – inclusion of requirements relating to policies, procedures and controls having regard to ML and TF risks and an independent audit function. • Chapter 3 – additional requirements for firms’ business risk assessments to consider the risks of the business being used for the most likely predicate offences for the Bailiwick specified in the NRA. • Chapter 7 – additional requirements on regulated trustees of relevant trusts and partners of relevant partnerships. • Chapter 18 – a new chapter including rules and guidance for virtual asset service providers and specified businesses with connections to, or involvement with, virtual assets. • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1) and more generally reflecting updates to all of the other Sources. 2.13, 2.17 - 2.32, 2.35, 2.36 3.35, 3.36, 3.53, 3.58 – 3.61, 3.107, 3.110 7.159 – 7.173 18.1 – 18.72 Appendix I – Country/territory changes Added to Appendix I: Chile, Croatia, Curaçao and Macau. Removed from Appendix I: Belize, Kiribati, Morocco and Rwanda. Appendix I – Relevant and External Sources links Sources 1 to 11 - links updated and threshold amended from 55 or more to 71 or more for Source 8.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 17 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 • General updates to remove and update references from NRFSB to LCF Law and from FIS to FIU, updates reflecting virtual assets, updating or removing references within the Handbook, the Enforcement Law, website links, proliferation financing guidance, additional risk factors and VASP references. • Updates to Appendices A, B, D, E, G and the Index per the above point. 1.7, 1.8, 1.22, 1.27, 1.28, 2.7, 2.9, 2.17, 2.37, 2.40, 2.45, 2.51, 2.55, 2.57, 2.59, 2.69, 2.80, 2.83, 2.84, 2.86, 2.88, 3.17, 3.37, 3.82, 3.85, 3.92, 3.100, 4.8, 4.37, 4.45, 4.48, 4.57, 4.63, 4.66, 4.67, 4.70, 4.76, 4.77, 6.22, 6.35, 7.50, 7.53, 7.57, 7.59, 7.65, 7.78, 7.87, 7.88, 7.89, 7.91, 7.93, 7.94, 7.95, 7.98, 7.99, 7.100, 7.101, 7.106, 7.108, 7.110, 7.114, 7.132, 7.140, 7.146, 7.147, 8.8, 9.59, 9.60, 9.72, 9.74, 11.38, 12.31, 13.8, 13.9, 13.12, 13.28, 13.29, 13.33, 13.35, 13.38, 13.40, 13.43 - 13.48, 13.51, 13.52 – 13.62, 13.65, 13.67, 13.69, 13.70, 13.71, 13.72, 13.75, 13.76, 13.78, 13.114 - 13.116, 14.5, 14.68, 14.69, 15.35, 15.37, 16.16, 16.17, 16.27, 16.30, 17.15, 17.16, 17.22, 17.33, 17.34, Appendix A, Appendix B, Appendix D – 21, 41, 63 & 64, Appendix E and Appendix G. References updated.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 18 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 6 November 2023 Handbook on Countering Financial Crime and Terrorist Financing updated Announcement: https://www.gfsc.gg/news/amlcft-handbook-appendices-c-and-i-updates Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1) • Appendix I – updated countries/territories from the Worldwide Governance Indicators project (Source 4) • Appendix I – updated countries/territories listed in United States Department of State: Trafficking in Persons Report (Source 5) Appendix C – Country/territory changes Removed from Appendix C: Bulgaria Appendix I – Country/territory changes Added to Appendix I: Bulgaria and Kazakhstan. Removed from Appendix I: Albania, Cayman Islands, Jordan, Moldova, Kosovo and Tunisia. Appendix I – Relevant and External Sources links Sources 1 and 5 – dates and links updated. Source 4 – date update.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 19 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 16 February 2024 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/updates-amlcftcpf-handbook Summary of changes Paragraphs affected • Front cover and acronyms – name of Handbook amended and additional acronyms included. • Chapter 1 – new guidance inserted to explain the definition of proliferation financing and updated information included on the NRA. • Chapter 3 – highlighting the specific limited definition of PF, including the requirement for a suitable and sufficient PF BRA, highlighting the specific limited definition of PF for PF BRA and NRA purposes and additions to other potential sources of risks and additional risk factors included. • Chapter 7 – additional requirements for firms’ business risk assessments to consider the risks of the business being used for the most likely predicate offences for the Bailiwick specified in the NRA. • Chapter 9 – removing “standards to combat ML and TF” and replacing with “measures” [consistent with the FATF Recommendations], updating factors considered in determination of Appendix C countries, including reference to FATF Recommendation 18, amendments to pooled account provisions to allow low risk non-financial services access and updates to associated rules. • Chapter 11 – additional high risk transactions red flag inserted. • Chapter 12 – updating introductory paragraphs explaining sanctions and relevant legislation, removal of the “Overview” section, updating information on the Bailiwick’s sanctions regime, removing EU references and updating legal references, including information on extra-territorial sanctions, inserting N/A 1.5, 1.33, 1.34 3.2, 3.32, 3.37, 3.38, 3.62, 3.101, 3.103, 3.113 7.123, 7.127 9.24, 9.33, 9.34, 9.74, 9.78 – 9.80 11.19 12.1, 12.2, 12.4 – 12.10, 12.12 – 12.16, 12.18 – 12.26, 12.28, 12.29, 12.36 – 12.40

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 20 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 guidance on the administration of the Bailiwick’s sanction regime, updating reporting obligations, updating terminology, amending information and rules to align with States of Guernsey website and relevant laws, updating guidance on published lists, inclusion of virtual assets and VASPs, guidance included regarding automated screening testing results to be reported to management, new rules created for firms to report sanctions connections to the Commission as well as to P&R and to maintain a register of reports made relating to sanctions and additional guidance relating to the new rules. • Chapter 13 – guidance updated in relation to reporting suspicion and the consent regime, inserting reference to the Information Regulations, updating guidance relating to PF offences and inserting additional guidance, links and potential red flags. • Chapter 17 – legislation updated to reflect requirements for firms to have a PF BRA and rule updated to include a transitional provision deadline for PF BRA. • Appendix A – inclusion of additional definitions relating to the 2020 Regulations, EFCB, Information Regulations, Proliferation Financing and TF offence. • Appendix I – Two sources updated, however does not include any additions or removals of countries. • General updates adding in PF or CPF as appropriate, changing FT to TF, adding in WMD, separating fraud and tax evasion as risks identified within the NRA, adding in reference to paragraph 16A of Schedule 3 to the legislative boxes where appropriate and updating paragraph cross-references. 13.2, 13.8, 13.9, 13.27, 13.32, 13.47, 13.61, 13.67, 13.72, 13.74 – 13.78, 13.117 17.6, 17.8 N/A Sources 6 and 8 - links updated. Throughout

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 21 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 7 March 2024 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/updates-amlcftcpf-handbook-0 Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1). • Appendix I – updated countries/territories from the TRACE Bribery Risk Matrix (Source 8). • Appendix I – updated countries/territories from the Transparency International: corruption perceptions index (Source 9). • Chapter 7 – changes made to the recognised stock exchanges to reflect changes in legislation. • Chapter 4 – minor change made to reflect a minor update to legislation. • Appendix G – changes made to reflect changes to legislation. Appendix I – Country/territory changes Source entries amended: Belarus, Burundi, Bolivia, Lao PDR, Egypt & Togo Removed from Appendix I: Gibraltar and the United Arab Emirates. Appendix I – Relevant and External Sources links Sources 1, 8 and 9 – dates and links updated. 7.59 (c) and (d) deleted, (e) ‘Stock’ changed to ‘Securities’, (m) and (n) added. 4.51 Updates made to paragraphs 9, 17 and 22(3).

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 22 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 13 March 2024 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/updates-amlcftcpf-handbook-1 Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1). Appendix I – Country/territory changes Added to Appendix I: Namibia

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 23 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 25 April 2024 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/updates-amlcftcpf-handbook-2 Summary of changes Paragraphs affected • Chapter 1 – new guidance inserted on failure to prevent money laundering and terrorist financing. • Chapter 2 – amendment to rule to include agents in AML/CFT/CPF programmes and monitor them for compliance. • Chapter 3 – update broken link. • Chapter 4 – amendment to paraphrased legislation and guidance to reflect changes made to legislation. • Chapter 7 – amendments to paraphrased legislation and rules and guidance amended to include a requirement to identify and verify the powers that regulate and bind the legal person/foundation/trust/legal arrangement; to include a requirement to consider reporting suspicious transactions or activity relating to high risk beneficiaries prior to any distribution; and to include requirements on those acting in equivalent positions to trustee or partner of relevant trusts or partnerships to foreign legal arrangements. • Chapter 8 – amendment to paraphrased legislation to include obtaining senior management approval for existing high risk business relationships with domestic or international organisation PEPs and amending reference to customer identification data to CDD information in rule. • Chapter 10 – guidance amended to include understanding the nature of the customer’s business in CDD measures. 11, 17 and 18. 62. 93. 20, 22, 23. 14, 30, 82, 97, 103, 148, 159, 160, 165 and 170 – 173. 7 and 89. 12.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 24 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 • Chapter 11 – amendment to paraphrased legislation to include obtaining senior management approval for existing high risk business relationships with domestic or international organisation PEPs. • Chapter 14 – amendments made to reflect legislative changes to the Transfer of Funds Ordinances. • Chapter 18 - amendments made to the paraphrased legislation, rules and guidance to reflect legislative changes to the thresholds for VASP payments. • Appendix A – updated definition of “customer due diligence”, “enhanced customer due diligence” and “occasional transaction” to reflect legislation changes and updated cross-reference to paragraph number relating to the definition of “guidance”. • Appendix G – changes made to reflect changes to legislation. 15. 17, 18, 25, 37 and 69. 10, 23, 32, 34, 37, 38, 43 and 44. N/A. N/A.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 25 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 19 July 2024 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/updates-amlcftcpf-handbook-3 Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1) • Appendix I – updated countries/territories from the UK HM Treasury sanctions (Source 7). Appendix I – Country/territory changes Added to Appendix I: Monaco Source entries amended: Venezuela, Jamaica, Turkey and Burundi.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 26 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 19 November 2024 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/amlcft-handbook-appendices-c-i-updates Summary of changes Paragraphs affected • Appendix C – Gibraltar added and hyperlinks updated. • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1). • Appendix I – updated countries/territories listed by the United States Department of State: International Narcotics Strategy Report of March 2023 – countries where proceeds from drug trafficking significantly affects the U.S.A. (Source 3). • Appendix I - updated countries/territories listed in United States Department of State: Trafficking in Persons Report (Source 5). • Appendix I – updated countries/territories from the US think-tank: Fund for Peace / Foreign Policy magazine: Fragile States Index (Source 10). • Appendix I – updated countries/territories from the Global Terrorism Index (Source 11). Appendix I – Country/territory changes Added to Appendix I: Belize Removed from Appendix I: Barbados, Chile and Senegal Source entries amended: Algeria, Angola, Bangladesh, Chad, Colombia, Cote d’Ivoire, Guinea Bissau, Haiti, Kenya, Lebanon, Philippines and Syria. Appendix I – Relevant and External Sources links Sources 1, 2, 3, 5 10 and 11 – dates and links updated.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 27 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 3 March 2025 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/updates-amlcftcpf-handbook-4 Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1). Appendix I – Country/territory changes Source entries amended: Lao PDR, Nepal and the Philippines.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 28 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 2 May 2025 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/updates-amlcftcpf-handbook-5 Summary of changes Paragraphs affected • Chapter 9 – amendments to pooled account provisions to extend access to subsidiary service companies of POI licensees. 9.74(c) and 9.75

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 29 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 4 July 2025 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/updates-amlcftcpf-handbook-6 Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1). Appendix I – Country/territory changes Added to Appendix I: British Virgin Islands Removed from Appendix I: Croatia Source entries amended: Bolivia, Mali and Tanzania.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 30 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 4 September 2025 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/amlcft-handbook-appendix-c-update Summary of changes Paragraphs affected • Appendix C – Malta added and hyperlinks updated. Appendix C – Country/territory changes Added to Appendix C: Malta

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 31 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 28 October 2025 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/amlcft-handbook-appendix-i-update-2 Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1). Appendix I – Country/territory changes Removed from Appendix I: South Africa Source entries amended: Burkina Faso, Mozambique, Nigeria.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 32 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 4 March 2026 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/amlcftcpf-handbook-appendix-i-update-0 Summary of changes Paragraphs affected • Appendix I – updated countries/territories listed as FATF jurisdictions under increased monitoring (Source 1). Appendix I – Country/territory changes Added to Appendix I: Kuwait Source entries amended: Papua New Guinea.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 33 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 5 May 2026 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/commission-paves-way-smarter-use-technology-compliance Summary of changes Paragraphs affected • Chapter 1 – amendment to language to encourage the use of technology; and updating guidance relating to MONEYVAL and the NRA. • Chapter 3 – update cross-references; and enhance section 3.12 on new and developing technologies, including around technology risk assessments. • Chapter 4 – update cross-references; technological references; align wording to the Electronic Transactions (Bailiwick of Guernsey) Law, 2000; include electronic translation guidance; include additional clarification in guidance; and remove reference to designated manager. • Chapter 5 – update technological references; include further guidance and new rules on technology risk assessments; and relocate some content from Chapter 6 into Chapter 5. • Chapter 6 – update guidance and rules around certification, including around electronic certification; relocate electronic verification from Chapter 6 into Chapter 5; and align wording to the Electronic Transactions (Bailiwick of Guernsey) Law, 2000; • Chapter 8 – update technological references. • Chapter 9 – update cross-references. • Chapter 17 – update cross-references. • Chapter 18 – clarify reference to electronic analytical tools; and broadening to 2, 14, 26, 35-39 and 42. 61, 68-73, 74, 86 and 89. 19, 23, 31, 33, 34, 37, 59, 64, 65, 67, 68, 71, 77 and 78. 21, 22, 26-28, 30, 31 and 33-39. 4, 5, 9, 10, 12-16, 19, 23-25, 29, 33 and 35. 8 and 25. 59 and 60. 33 and 34. 18 and 68.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 34 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 awareness to all firms of risk factors associated with VASPs. • Appendix A – update cross-references. • Appendix D – update technological references; and remove reference to designated manager. • Appendix G – changes made to reflect minor edits to consolidated text. N/A. 13, 39 and 61. N/A.

Record of changes to the Handbook on Countering Financial Crime (AML/CFT/CPF) 1 1 March 2019 – 8 May 2026 35 | P a g e 1The name of the Handbook was changed from Handbook on Countering Financial Crime and Terrorist Financing on 16 February 2024 8 May 2026 Handbook on Countering Financial Crime (AML/CFT/CPF) updated Announcement: https://www.gfsc.gg/news/updates-amlcftcpf-handbook-7 Summary of changes Paragraphs affected • Chapter 7 – updating guidance relating to beneficial ownership information on a company registry and board composition of ICCs and ICs. • Chapter 9 – amend reference from designated manager to designated administrator. • Chapter 10 – include clarification in rules and guidance regarding introduced relationships by a firm using an electronic verification system. • Chapter 16 – update reference to include distributed ledger technology. • Appendix F – include information regarding electronically verified identification data. 57 and 70. 22. 12, 14 and 17. 32. N/A.