Financial Flows Return (Form 153) Guidance

Financial Crime Division Financial Flows Return (Form 153) Guidance for Completion 4 June 2025 Version Date Summary of Changes 4 June 2025 Guidance document updated and re-issued following revisions to the Financial Flows Return (Form 153).

Financial Crime Division Financial Crime Risk – Financial Flows Return Guidance 4 June 2025 Contents Page 2 Contents Contents.....................................................................................................................................2 Glossary of Terms......................................................................................................................3 Introduction................................................................................................................................5 Start Page ...................................................................................................................................6 Payment Methods.......................................................................................................................7 Correspondent Banking (Domestic & Foreign).........................................................................8 Financial Flows Statistical Information .....................................................................................9 Declaration...............................................................................................................................13

Financial Crime Division Financial Crime Risk – Financial Flows Return Guidance 4 June 2025 Glossary of Terms Page 3 Glossary of Terms ‘Bailiwick’ The Bailiwick of Guernsey. ‘Commission’ The Guernsey Financial Services Commission ‘Correspondent’ A financial institution which provides services such as payment processing to a Respondent (which receives the services). ‘Firm’ The Licenced Bank or Non-Bank MSP completing the Return. ‘Helpdesk’ The Commission’s Online Submissions Portal Helpdesk which can be contacted via telephone on +44 1481 712706 or e-mail: support@gfsc.gg ‘Licenced Bank’ A financial services business licenced under The Banking Supervision (Bailiwick of Guernsey) Law, 2020. ‘ML’ Money laundering. ‘Non-Bank MSP’ A business undertaking the activities set out in paragraphs 4 or 6 of Schedule 1 to the Proceeds of Crime Law (excluding the provision of currency exchange (bureau de change) or cheque cashing services) and registered by the Commission under Schedule 4 to the Proceeds of Crime Law. ‘Online Submissions Portal’ The Commission’s Online Submissions Portal, accessible via https://submit.gfsc.gg/ ‘PF’ Proliferation financing. ‘Proceeds of Crime Law’ The Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999.

Financial Crime Division Financial Crime Risk – Financial Flows Return Guidance 4 June 2025 Glossary of Terms Page 4 ‘Reporting Period’ The quarter and year specified within the form on the Online Submissions Portal. ‘Respondent’ A financial institution which receives services such as payment processing from a Correspondent. ‘Return’ The Financial Flows Return, accessible via the Online Submissions Portal. ‘TF’ Terrorist financing.

Financial Crime Division Financial Crime Risk – Financial Flows Return Guidance 4 June 2025 Introduction Page 5 Introduction The Commission is collecting information on the origin and destination of funds flowing through the Bailiwick and associated payment methods to assist in assessing the financial crime risks within individual Firms and within the Bailiwick as a whole. All Licenced Banks and Non-Bank MSPs (referred to as Firms in this document) are required to submit the Return. Data collected through this Return complements data collected through other means such as the annual Financial Crime Risk Return. Whilst the information will be primarily used for supervisory purposes, the Commission may periodically share data on financial flows and payment methods with other Bailiwick domestic authorities for the purpose of the exercise of their functions or for exercises such as the national risk assessment. The purpose of the Return is to capture data on the origin and destination of client-related financial flows and associated information to assist in understanding how these transactions are made. Where a Firm has no qualifying inflows or outflows for the Reporting Period, it is still required to complete the Return, however the financial flows statistical spreadsheet may be a ‘nil return’ by leaving the value and volume fields blank within the financial flows statistics spreadsheet uploaded to the Return. The Reporting Period for the Return is each calendar quarter commencing 1 January and will become available for submission on the Firm’s Online Submissions Portal timeline on the last day of each quarter. The Return must be submitted within 2 months of quarter end and is within scope of administrative financial penalties being imposed where late and/or inaccurate submissions are made. Reporting Period Start Reporting Period End Submission Deadline 1 January 31 March 31 May 1 April 30 June 31 August 1 July 30 September 30 November 1 October 31 December Last day of February This guidance has been issued to assist with the completion and submission of the Return. Further guidance on the use of the Online Submissions Portal and how to begin completion of the Return can be found at https://submit.gfsc.gg/faq/ If you encounter any difficulty in completing the Return or have any questions about the information to be provided, please contact the Commission’s Helpdesk via telephone on +44 1481 712706 or by e￾mailing support@gfsc.gg

Financial Crime Division Financial Crime Risk – Financial Flows Return Guidance 4 June 2025 Start Page Page 6 Start Page Having selected to complete the Return from the Online Submissions Portal, the form will open on the ‘Start’ page. The ‘Start’ page provides details about the background to the Return but has no questions requiring completion. ‘Company Name’ This field is read-only and should display the name of the Firm required to submit the Return. Therefore if the name reflected is not that of the Firm completing the Return or if the Firm’s name is not displayed correctly, do not progress further and, instead, contact the Commission’s Helpdesk. ‘Year’ This field is read-only and is automatically populated with the year of the Reporting Period. Should this not be the case, please do not progress further and, instead, contact the Commission’s Helpdesk. ‘Quarter’ This field is read-only and is automatically populated with the calendar quarter of the Reporting Period. Should this not be the case, please do not progress further and, instead, contact the Commission’s Helpdesk. Click ‘Create’ / ‘Next’ to continue.

Financial Crime Division Financial Crime Risk – Financial Flows Return Guidance 4 June 2025 Payment Methods Page 7 Payment Methods Please respond to these questions with answers reflecting the position as at the end of the Reporting Period, not the position as at the time of completion/submission. ‘Which of the following transfer systems does the Firm use to send or receive funds?’ Please select all transfer systems which are used by the Firm. If a system used by the Firm is not listed, please select the ‘Other’ box and provide brief details in the associated ‘Details of Other’ free text box. ‘Select as appropriate if the Firm’ This question is in relation to the products/services and methods of payment that the Firm offers/utilises. ‘Allows physical cash withdrawals’ means allowing customers to withdraw physical cash from their account and includes withdrawal via ATMs or over the counter. ‘Virtual IBANs’ are also known as virtual accounts. These accounts have their own IBANs but are connected to a master, primary, or central account and are often used to facilitate more efficient reconciliation of payments. If the Firm issues such accounts for use by its customers, please select this box. ‘Issues Cheques’ should only be selected if a Firm issues cheque books for its customers to use as a method of payment, not if the Firm issues cheques in its own name. ‘Does the Firm rely on another Guernsey Bank for the provision of bank accounts’ Examples of this will include where a non-clearing bank or non-bank MSP does not have its own sorting code / SWIFT / BIC and instead utilises the services of another bank in order to, in-turn, provide accounts to its own customers. As text is entered into this field, a list of suggested entities will appear. Only Guernsey Licensed Banks will appear and thus only those can be selected. If a Guernsey Licensed Bank is not appearing as expected within the list, please contact the Commission’s Helpdesk.

Financial Crime Division Financial Crime Risk – Financial Flows Return Guidance 4 June 2025 Correspondent Banking (Domestic & Foreign) Page 8 Correspondent Banking (Domestic & Foreign) To assist with completion, a number of fields within this tab will auto-populate with the information provided in the previous quarter’s Return. Fields which contain the auto-populated information are those which are likely to remain relatively static. The Firm must review and, where any auto-populated information differs from the position as at the end of the current Reporting Period, update the fields. ‘Does the Firm provide correspondent services to other Guernsey licensed banks? (i.e. acting as a correspondent)’ If yes, a table will appear and as text is entered a list of suggested entities will appear. Only Guernsey Licensed Banks will appear and thus only those can be selected. If a Guernsey Licensed Bank is not appearing as expected within the list, please contact the Helpdesk. Please provide the names of all Guernsey Licenced Banks that the Firm provides Correspondent services to during as at the end of the Reporting Period. ‘Does the Firm utilise correspondent services of other Guernsey licensed banks? (i.e. acting as a respondent)’ If yes, a table will appear and as text is entered a list of suggested entities will appear. Only Guernsey Licensed Banks will appear and thus only those can be selected. If a Guernsey Licensed Bank is not appearing as expected within the list, please contact the Helpdesk. Please provide the names of all Guernsey Licenced Banks that the Firm utilises the Correspondent services of as at the end of the Reporting Period. ‘With regard to making GBP, EUR, USD and CHF payments, does the Firm use correspondents, whether in-house (including group) correspondents, external correspondents, or both?’ If yes, a table will appear to complete. Please provide details of the Correspondent relationships in place as at the end of the Reporting Period for each currency. This should include both Guernsey and non￾Guernsey Correspondents. Multiple Correspondents per currency and per type can be entered. ‘Has the Firm’s usage of external correspondents (any currency) changed during the reporting period?’ If yes, please provide detail on how the Firm’s usage of external Correspondents has changed during the Reporting Period, and the reasons for change. ‘During the reporting period, have any of the Firm's external correspondents (any currency) advised that their risk appetite has changed in respect of acting as a correspondent?’ If yes, please provide detail on how the Correspondent’s risk appetite has changed in relation to customer types, products and services which the Correspondent will no longer service. This should also include, where known, whether this was a change to the services provided specifically to the Firm or whether it was a broader risk appetite change of the Correspondent e.g. no longer servicing certain customer types, products/services, regions/jurisdictions, or currencies. The Commission appreciates that the Firm may not hold all information in relation to the change in risk appetite of the Correspondent and that this question will be answered on a ‘best endeavours’ basis.

Financial Crime Division Financial Crime Risk – Financial Flows Return Guidance 4 June 2025 Financial Flows Statistical Information Page 9 Financial Flows Statistical Information Linked within the Return is a spreadsheet which the Firm is required to complete with the values and volumes of its flows with all jurisdictions. The spreadsheet is required to be completed for each quarter. The spreadsheet has one tab for completion and only the green coloured cells within the spreadsheet are able to be selected and/or have values entered. Once all of the requested information has been provided, the completed spreadsheet should be uploaded back to the Return by using the ‘Upload a document’ function of the Return. Please do not encrypt (password protect) the version of the spreadsheet that is uploaded. The portal uses a secure HTTPS connection to encrypt all communications. Only one file can be uploaded and it must be in an .xlsx format and no larger than 15MB, otherwise it will be rejected by the Online Submissions Portal when attempting to upload. If the Firm wishes to amend/replace the file uploaded, please click the [ X ] under the ‘Delete’ column and reupload the amended spreadsheet. ‘Firm Name’ The name entered must exactly match the name of the Firm otherwise the statistics spreadsheet will be rejected by the Online Submissions Portal when attempting to upload it. The exact name can be found by searching for the Firm on the ‘Regulated Entities’ page of the Commission’s website: https://www.gfsc.gg/commission/regulated-entities ‘GFSC Reference’ The value entered here should be numerical only and match the Firm’s reference number given by the Commission otherwise the statistics spreadsheet will be rejected by the Online Submissions Portal when attempting to upload it. If not known, this can be found by searching for the Firm on the ‘Regulated Entities’ page of the Commission’s website: https://www.gfsc.gg/commission/regulated-entities

Financial Crime Division Financial Crime Risk – Financial Flows Return Guidance 4 June 2025 Financial Flows Statistical Information Page 10 ‘Reporting Period End Date’ Please select the appropriate period end from the dropdown list provided. This date must match the Reporting Period of the Return otherwise the statistics spreadsheet will be rejected by the Online Submissions Portal when attempting to upload it. The Reporting Period end date can be found on the ‘Start’ tab of the Return. Financial Flows Geographic Data The purpose of the Return is to capture data on the origin and destination of client-related financial flows and associated information to assist in understanding how these transactions are made. Where a Firm has no qualifying inflows or outflows for the Reporting Period, it is still required to complete the Return, however the financial flows statistical spreadsheet may be a ‘nil return’ by leaving the value and volume fields blank within the financial flows statistics spreadsheet. Format of data entry Please ensure that flow values as whole numbers (rounded up/down as appropriate). For example, 1520.46 should be entered as 1520. Aggregation of flows The inflows columns should reflect the total value and volume of all payments received by the Firm from the relevant jurisdiction. The outflows columns should reflect the total value and volume of all payments made by the Firm to the relevant jurisdiction. Currency of flows Please provide values in their GBP equivalent regardless of the original currency of the transaction. The conversion of values into GBP should be as at the date of the transaction or, where this is not possible, the Firm may use the exchange rate as at the date of the end of the Reporting Period. Determination of Origin/Destination of flows Where the Firm has accounts with its parent/head office and funds flow into or out of accounts at the parent bank on behalf of a client, the data to be reported should reflect the geographic location of the remitting or beneficiary bank and not the locations of the accounts. For example a Firm may hold its accounts at its head office in the UK and it may effect a transfer for a client to an account with its sister bank in the Cayman Islands which also holds its accounts with the parent bank in the UK. For the purposes of this Return, in this example the outflow should be recorded against the Cayman Islands. In the opposite scenario, the inflow should be recorded against the Cayman Islands. Branches with shared sort codes / BICs For Firm’s which are branches, please only report transactions undertaken through the Guernsey based branches (i.e. using the branch’s sort codes/BICs). Where the Guernsey branch shares a sort code/BIC with a branch in a different jurisdiction, only the Guernsey branch transactions should be reported.

Financial Crime Division Financial Crime Risk – Financial Flows Return Guidance 4 June 2025 Financial Flows Statistical Information Page 11 Correspondents / Respondents Where a Firm acts as a Correspondent, it should not include the financial flows of Respondent entities within its own financial flows reporting as the Respondent entities are responsible for reporting their own financial flows. Similarly, Respondents must ensure they report their own financial flows, even if these are via Correspondents. Any exceptions to this should be discussed with the Commission’s Financial Crime Division via amlcft@gfsc.gg well in advance of the submission deadline of the Return. Intra/Inter-bank flows The purpose of the Return is to capture data on the origin and destination of client-related financial flows. As such, intra/inter-bank transactions should be excluded where those transactions do not originate from or are destined for a particular client but instead arise as a result of: • upstreaming to parent entities; • fulfilling group treasury functions; • investment in treasury bills (T-Bills) or other cash management activities; or • intra/inter-bank placements such as Swiss fiduciary deposits. If the Firm is unsure whether a certain activity/flow type should be reported within the financial flows statistics spreadsheet or not, please discuss this with the Commission’s Financial Crime Division via amlcft@gfsc.gg well in advance of the submission deadline of the Return. List of territories that should be reported under their governing state The following territories are not present within the statistics spreadsheet and their flows must be reported under their Governing State as one consolidated value. Code Territory Governing State AS American Samoa United States AX Åland Islands Finland BL Saint Barthélemy France BV Bouvet Island Norway CC Cocos Islands Australia CK Cook Islands New Zealand CX Christmas Islands Australia GF French Guiana France GP Guadeloupe France GS South Georgia & South Sandwich Islands United Kingdom GU Guam United States HM Heard & McDonald Islands Australia IO British Indian Ocean Territory (comprises Chagos Archipelago) United Kingdom MC Monaco France MF Saint Martin (French part) France MP Northern Mariana Islands United States MQ Martinique France NF Norfolk Island Australia NU Niue New Zealand

Financial Crime Division Financial Crime Risk – Financial Flows Return Guidance 4 June 2025 Financial Flows Statistical Information Page 12 PM Saint Pierre and Miquelon France PN Pitcairn United Kingdom PR Puerto Rico United States RE Réunion France SH Saint Helena, Ascension & Tristan da Cunha United Kingdom SJ Svalbard & Jan Mayen Norway TK Tokelau New Zealand UM United States Minor Outlying Islands United States VI US Virgin Islands United States YT Mayotte France ‘Describe the main drivers for the Firm's flows by value, including high level commentary regarding the nature of customers' underlying activities; which markets (such as retail banking, commercial banking, collective investment schemes, private wealth management, mortgages, non-mortgage lending, trade finance); and which regions/countries (such as Europe, USA, Middle East, UK).’ Please provide a high-level explanation of the drivers for the Firm’s financial flows value as a whole. The Commission does not expect numerical data/analysis of flows to be provided here; rather, commentary is expected from the Firm regarding what customer activities/markets predominantly drive its flows by value. It is however expected that the Firm understands enough about the activity of its customers, the products/services offered, and the regions in which it offers these products, together with sufficient reporting and understanding of its pattern of flows, to be able to provide commentary about its flow values. This may include commentary about how its flow values are driven by specific types of customers that the Firm has, specific products/services it offers, the regions/jurisdictions that the Firm has customers from, or the types of financial services firms/sectors the Firm services. ‘Describe the main drivers for the Firm's flows by volume, including high level commentary regarding the nature of customers' underlying activities; which markets (such as retail banking, commercial banking, collective investment schemes, private wealth management, mortgages, non-mortgage lending, trade finance); and which regions/countries (such as Europe, USA, Middle East, UK).’ Please provide a high-level explanation of the drivers for the Firm’s financial flows volume as a whole. The Commission does not expect numerical data/analysis of flows to be provided here; rather, commentary is expected from the Firm regarding what customer activities/markets predominantly drive its flows by volume. It is however expected that the Firm understands enough about the activity of its customers, the products/services offered, and the regions in which it offers these products, together with sufficient reporting and understanding of its pattern of flows, to be able to provide commentary about its flow volumes. This may include commentary about how its flow volumes are driven by specific types of customers that the Firm has, specific products/services it offers, the regions/jurisdictions that the Firm has customers from, or the types of financial services firms/sectors the Firm services.

Financial Crime Division Financial Crime Risk – Financial Flows Return Guidance 4 June 2025 Declaration Page 13 ‘Have there been any significant internal/external events or changes to the Firm that would have caused a material change to the flow value or volume overall for the period compared to the previous periods?’ If yes, please provide a high-level explanation for any relevant changes to the Firm’s flows overall for this Reporting Period compared to previous Reporting Periods. Examples could include that the Firm has seen an increased level of private equity investment activity by its clients which has increased both the inflows and outflows by value; the Firm has launched a new product which has caused an increase in flows; or that macroeconomic factors such as interest rates, changes in the political landscape, or new legislation or technologies have impacted on the Firm’sflows. If the Firm typically observes changes in its flows patterns for specific quarters such as end of calendar/financial year activity causing a change in flows, please also provide details of this here. ‘Have there been any significant internal/external events or changes to the Firm that would have caused a material change to the flow value or volume to a specific country for the period compared to the previous periods?’ If yes, please provide a high-level explanation for any relevant changes to the Firm’s flows with a specific country for this Reporting Period compared to previous Reporting Periods. Examples could include that the Firm has acquired a new book of business from another Firm which had customers from specific countries/regions; or that the Firm has onboarded a significant new institutional customer which has a focus on investment activity in specific countries/regions. ‘How does the Firm monitor flows to/from countries/regions which present a higher risk of ML, TF and PF?’ Please provide a high-level explanation of how the Firm monitors flows with countries/regions which present a higher risk of ML / TF / PF including how this differs from monitoring of flows with countries/regions which do not present a higher risk of ML / TF / PF. ‘Attach a list detailing those countries that the Firm considers to present a higher risk of ML / TF / PF in respect of financial flows’ Where possible, please provide the attachment in an Excel format clearly showing if the country is considered to present a higher risk of ML, TF and/or PF. ‘Please provide any other relevant information for the Commission regarding this submission’ Please use this field to provide any further information you feel is pertinent to the subject of the Return which has not been covered by any of the questions previously asked. Declaration Once the Firm is satisfied that the Return has been fully completed, the user should select the ‘I agree to the above’ field, provide their name and click ‘Submit’. If the form has been successfully submitted a pop-up will appear confirming so and a ‘Thank You’ tab will appear on the form. The date and time of submission is displayed at the top of the page.