2020-11-23
The Guernsey Financial Services Commission issued this July 2012 document to summarize findings from 94 on-site inspections of financial services businesses regarding their Anti-Money Laundering and Counter-Terrorist Financing compliance. The regulator identified widespread issues including generic business risk assessments that fail to reflect specific operational models, inadequate documentation for high-risk customer classifications, and insufficient specialized training for senior management and MLROs. Additionally, the Commission highlighted deficiencies in monitoring procedures, record retrievability, and sanctions list monitoring capabilities among smaller firms lacking automated software.