Guernsey Financial Services Commission Instructions and Notices Record of Changes

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 1 | P a g e Date / Recipient Title Particulars /Action to be Taken 15 December 2007 Financial Services Businesses (“FSBs”) Business from Sensitive Sources Notice (Number 5) FSBs were to apprise themselves of changes to the list of monitored countries and territories, and exercise a greater degree of caution when taking on business from jurisdictions subject to the FATF’s monitoring process. Notice (Number 5) lists concerns in relation to Myanmar, Islamic Republic of Iran, Venezuela, West Africa (Morocco, Mauritania, Senegal, Cape Verde, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). From 15 December 2007, the following no longer had effect:
 Business from Sensitive Sources Notice (Number 1) – issued 18/11/99  Business from Sensitive Sources Notice (Number 2) – issued 27/07/00  Business from Sensitive Sources Notice (Number 3) – issued 04/10/01  Business from Sensitive Sources Notice (Number 4) – issued 22/08/02 10 April 2008 FSBs Business From Sensitive Sources Notice (Number 6) Financial services businesses were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Notice. Additionally, FSBs were to ensure enhanced customer due diligence measures were undertaken and special attention was given to all business relationships and transactions connected with the countries or territories listed below. Notice (Number 6) lists concerns in relation to Myanmar, Uzbekistan, Iran, Pakistan, Turkmenistan, Sao Tomé and Principe and northern part of Cyprus, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Notice (Number 5) repealed.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 2 | P a g e Date / Recipient Title Particulars /Action to be Taken 9 October 2008 Prescribed Businesses (“PBs”) Business from Sensitive Sources Notice (Number 1) PBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Notice. Additionally, PBs were to ensure special attention was given to all business relationships and transactions connected with the countries or territories listed below. Notice (Number 1) lists concerns in relation to Myanmar, Uzbekistan, Iran, Pakistan, Turkmenistan, Sao Tomé and Principe and northern part of Cyprus, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). 18 February 2009 FSBs Business From Sensitive Sources Notice (Number 7) FSBs were to exercise a greater deal of caution when taking on business from the countries or territories specified in this Notice. Additionally, FSBs were to ensure enhanced customer due diligence measures were undertaken and special attention was given to all business relationships and transactions connected with the countries and territories listed below. Notice required that greater caution by exercised by applying enhanced due diligence to all business relationships and transactions connected with Azerbaijan. Notice (Number 7) lists concerns in relation to Myanmar, Uzbekistan, Iran, Pakistan, Turkmenistan, Sao Tomé and Principe and northern part of Cyprus, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Notice (Number 6) repealed.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 3 | P a g e Date / Recipient Title Particulars /Action to be Taken 18 February 2009 PBs Business From Sensitive Sources Notice (Number 2) PBs were to exercise a greater deal of caution when taking on business from the countries or territories specified in this Notice. Additionally, PBs were to ensure enhanced customer due diligence measures were undertaken and special attention was given to all business relationships and transactions connected with the countries and territories listed below. Notice required that greater caution be exercised by applying enhanced due diligence to all business relationships and transactions connected with Azerbaijan. Notice (Number 2) lists concerns in relation to Myanmar, Uzbekistan, Iran, Pakistan, Turkmenistan, Sao Tomé and Principe and northern part of Cyprus, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Notice (Number 1) repealed. 13 March 2009 FSBs Business From Sensitive Sources Notice (Number 8) FSBs were to exercise a greater deal of caution when taking on business from the countries or territories specified in this Notice. Additionally, FSBs were to ensure enhanced customer due diligence measures were undertaken and special attention was given to all business relationships and transactions connected with such countries and territories. Notice lists concerns in relation to Myanmar, Uzbekistan, Iran, Pakistan, Turkmenistan, Sao Tomé and Principe, and northern part of Cyprus, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana) and Azerbaijan. Notice (Number 7) repealed.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 4 | P a g e Date / Recipient Title Particulars /Action to be Taken 13 March 2009 PBs Business From Sensitive Sources Notice (Number 3) PBs were to exercise a greater deal of caution when taking on business from the countries or territories specified in this Notice. Additionally, PBs were to ensure enhanced customer due diligence measures were undertaken and special attention was given to all business relationships and transactions connected with the countries and territories listed below. Notice (Number 3) lists concerns in relation to Myanmar, Uzbekistan, Iran, Pakistan, Turkmenistan, Sao Tomé and Principe, and northern part of Cyprus, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana) and Azerbaijan. Notice (Number 2) repealed. 5 May 2009 FSBs Business From Sensitive Sources Notice (Number 9) FSBs were to exercise a greater deal of caution when taking on business from the countries or territories specified in this Notice. Additionally, FSBs were to ensure enhanced customer due diligence measures were undertaken and special attention was given to all business relationships and transactions connected with the countries and territories listed below. In light of the particular concerns of the FATF regarding Iran, FSBs were to, in addition to the requirements of the above paragraph: • review and consider any existing business relationships with Iran to ascertain whether any action is needed; and • take appropriate measures to ensure that correspondent relationships were not being used to bypass or evade counter-measures and risk mitigation practices. Notice (Number 9) lists concerns in relation to Myanmar, Uzbekistan, Iran, Pakistan, Turkmenistan, Sao Tomé and Principe, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana) and Azerbaijan.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 5 | P a g e Date / Recipient Title Particulars /Action to be Taken Notice (Number 8) repealed. 5 May 2009 PBs Business From Sensitive Sources Notice (Number 4) PBs were to exercise a greater deal of caution when taking on business from the countries or territories specified in this Notice. Additionally, PBs were to ensure that enhanced customer due diligence measures were undertaken and special attention given to all business relationships and transactions connected with the countries and territories listed below. In light of the particular concerns of the FATF regarding Iran, PBs were to, in addition to the requirements of the above paragraph: • review and consider any existing business relationships with Iran to ascertain whether any action was needed; and • take appropriate measures to ensure that correspondent relationships were not being used to bypass or evade counter-measures and risk mitigation practices. Notice (Number 4) lists concerns in relation to Myanmar, Uzbekistan, Iran, Pakistan, Turkmenistan, Sao Tomé and Principe, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana) and Azerbaijan. Notice (Number 3) repealed. 11 November 2009 FSBs Instruction (Number 7) FSBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, FSBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. In light of the particular concerns regarding Iran, FSBs were to, in addition to the requirements of the above paragraph: • review and consider any existing business

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 6 | P a g e Date / Recipient Title Particulars /Action to be Taken relationships with Iran to ascertain whether any action was needed; and • take appropriate measures to ensure that correspondent relationships were not being used to bypass or evade counter-measures and risk mitigation practices. The action taken by each FSB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 7) lists concerns in relation to Myanmar, Uzbekistan, Iran, Pakistan, Turkmenistan, Sao Tomé and Principe, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana) and Azerbaijan. Notice (Number 9) repealed. 11 November 2009 PBs Instruction (Number 5) PBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, PBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. In light of the particular concerns regarding Iran, PBs were to, in addition to the requirements of the above paragraph: • review and consider any existing business relationships with Iran to ascertain whether any action was needed; and • take appropriate measures to ensure that correspondent relationships were not being used to bypass or evade counter-measures and risk mitigation practices. The action taken by each PB under this Instruction would be reviewed during on-site inspections and by other means as necessary.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 7 | P a g e Date / Recipient Title Particulars /Action to be Taken Instruction (Number 5) lists concerns in relation to Myanmar, Uzbekistan, Iran, Pakistan, Turkmenistan, Sao Tomé and Principe, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana) and Azerbaijan. Notice (Number 4) repealed. 11 November 2009 FSBs Instruction (Number 8) The Commission required that FSBs must immediately consider whether or not they have any exposure to the following persons and, if they have any exposure, they are requested to advise Kevin Bown of the Commission’s intelligence team accordingly. Action taken by each FSB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 6) lists concerns about certain persons arising from the impact of the Financial Restrictions (Iran) Order 2009 was made by HM Treasury on 9 October 2009:

• Bank Mellat (head office is located at No. 327 Talegnai Avenue, Tehran 15817, Iran);
• Islamic Republic of Iran Shipping Lines (“IRISL”) (address provided as No. 37, Aseman
  Tower, Sayyade Square, Pasdran Avenue, Tehran, Iran); and
• a branch of either Bank Mellat or IRISL wherever they are located.
  11 November 2009
  PBs
  Instruction
  (Number 6)
  The Commission required that PBs must immediately consider whether or not they have any exposure to the following persons and, if they have any exposure, they are requested to advise Kevin Bown of the Commission’s intelligence team accordingly.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 8 | P a g e Date / Recipient Title Particulars /Action to be Taken Action taken by each PB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 6) lists concerns about certain persons arising from the impact of the Financial Restrictions (Iran) Order 2009 was made by HM Treasury on 9 October 2009:

• Bank Mellat (head office is located at No. 327 Talegnai Avenue, Tehran 15817, Iran);
• Islamic Republic of Iran Shipping Lines (“IRISL”) (address provided as No. 37, Aseman
  Tower, Sayyade Square, Pasdran Avenue, Tehran, Iran); and
• a branch of either Bank Mellat or IRISL wherever they are located.
  9 March 2010
  FSBs
  Instruction
  (Number 9)
  FSBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, FSBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. The action taken by each FSB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 9) lists concerns in relation to Iran, Angola, Azerbaijan, Democratic People’s Republic of Korea (“DPRK”), Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Greece, Indonesia, Kenya, Myanmar, Nepal, Nigeria, Paraguay, Qatar, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Thailand, Turkey, Ukraine, Yemen, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana).

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 9 | P a g e Date / Recipient Title Particulars /Action to be Taken Instruction (Number 7) repealed. 9 March 2010 PBs Instruction (Number 7) PBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, PBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. The action taken by each PB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 7) lists concerns in relation to Iran, Angola, Azerbaijan, Democratic People’s Republic of Korea (“DPRK”), Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Greece, Indonesia, Kenya, Myanmar, Nepal, Nigeria, Paraguay, Qatar, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Thailand, Turkey, Ukraine, Yemen, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Instruction (Number 5) repealed. 5 July 2010 FSBs Instruction (Number 10) FSBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, FSBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. The action taken by each FSB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 10) lists concerns in relation to Iran, Angola, Azerbaijan, Democratic

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 10 | P a g e Date / Recipient Title Particulars /Action to be Taken People’s Republic of Korea (“DPRK”), Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Greece, Indonesia, Kenya, Myanmar, Nepal, Nigeria, Paraguay, Qatar, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Thailand, Turkey, Ukraine, Yemen, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Instruction (Number 9) repealed. 5 July 2010 PBs Instruction (Number 8) PBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, PBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. The action taken by each PB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 8) lists concerns in relation to Iran, Angola, Azerbaijan, Democratic People’s Republic of Korea (“DPRK”), Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Greece, Indonesia, Kenya, Myanmar, Nepal, Nigeria, Paraguay, Qatar, Sri Lanka, Sudan, Syria, Trinidad and Tobago, Thailand, Turkey, Ukraine, Yemen, Venezuela and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Instruction (Number 7) repealed. 30 July 2010 FSBs Letter to FSBs FSBs advised that, as identified in Instruction (Number 10) issued on 5 July 2010, Greece continued to be included on the list of jurisdictions which the FATF considered to have strategic AML/CFT deficiencies. The Commission decided to remove Greece from

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 11 | P a g e Date / Recipient Title Particulars /Action to be Taken
Appendix C to the Handbook for Financial Services Businesses on Countering Financial
Crime and Terrorist Financing.
Whilst existing business relationships through introducers in Greece could be maintained, subject to the requirements of Instruction (Number 10), FSBs could not accept any new introduced business with entities in Greece even where the introducer was an existing introducer. 6 December 2010 FSBs Instruction (Number 11) FSBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, FSBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. The action taken by each FSB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 11) lists concerns in relation to Iran, Angola, Democratic People’s Republic of Korea (“DPRK”), Bangladesh, Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Greece, Honduras, Indonesia, Kenya, Myanmar, Nepal, Nigeria, Paraguay, Philippines, Qatar, Sri Lanka, Sudan, Syria, Tanzania, Trinidad and Tobago, Thailand, Turkey, Ukraine, Yemen, Venezuela, Vietnam and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana) and Azerbaijan. Instruction (Number 10) repealed. 6 December 2010 Instruction (Number 9) PBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, PBs were to ensure that

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 12 | P a g e Date / Recipient Title Particulars /Action to be Taken PBs enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. The action taken by each PB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 9) lists concerns in relation to Iran, Angola, Democratic People’s Republic of Korea (“DPRK”), Bangladesh, Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Greece, Honduras, Indonesia, Kenya, Myanmar, Nepal, Nigeria, Paraguay, Philippines, Qatar, Sri Lanka, Sudan, Syria, Tanzania, Trinidad and Tobago, Thailand, Turkey, Ukraine, Yemen, Venezuela, Vietnam and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana) and Azerbaijan. Instruction (Number 8) repealed. 5 April 2011 FSBs Instruction (Number 12) FSBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, FSBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. The action taken by each FSB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Notice (Number 12) lists concerns in relation to Iran, Angola, Democratic People’s Republic of Korea (“DPRK”), Bangladesh, Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Greece, Honduras, Indonesia, Kenya, Myanmar, Libya, Nepal, Nigeria, Paraguay, Philippines, Sri Lanka, Sudan, Syria, Tanzania,

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 13 | P a g e Date / Recipient Title Particulars /Action to be Taken Trinidad and Tobago, Thailand, Turkey, Ukraine, Yemen, Venezuela, Vietnam and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Instruction (Number 11) repealed. 5 April 2011 PBs Instruction (Number 10) PBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, PBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. The action taken by each PB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 10) lists concerns in relation to Iran, Angola, Democratic People’s Republic of Korea (“DPRK”), Bangladesh, Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Greece, Honduras, Indonesia, Kenya, Myanmar, Libya, Nepal, Nigeria, Paraguay, Philippines, Sri Lanka, Sudan, Syria, Tanzania, Trinidad and Tobago, Thailand, Turkey, Ukraine, Yemen, Venezuela, Vietnam and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Instruction (Number 9) repealed. 3 August 2011 FSBs Instruction (Number 13) FSBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, FSBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 14 | P a g e Date / Recipient Title Particulars /Action to be Taken The action taken by each FSB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 13) lists concerns in relation to Iran, Angola, Argentina, Brunei Darussalam, Cambodia, Democratic People’s Republic of Korea (“DPRK”), Bangladesh, Cuba, Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Greece, Honduras, Indonesia, Kenya, Myanmar, Mongolia, Libya, Namibia, Nepal, Nicaragua, Nigeria, Paraguay, Philippines, Sri Lanka, Sudan, Syria, Tajikistan, Tanzania, Trinidad and Tobago, Thailand, Turkey, Ukraine, Yemen, Venezuela, Vietnam, Zimbabwe and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Instruction (Number 12) repealed. 3 August 2011 PBs Instruction (Number 11) PBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, PBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. The action taken by each PB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 11) lists concerns in relation to Iran, Angola, Argentina, Brunei Darussalam, Cambodia, Democratic People’s Republic of Korea (“DPRK”), Bangladesh, Cuba, Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Greece, Honduras, Indonesia, Kenya, Myanmar, Mongolia, Libya, Namibia, Nepal, Nicaragua, Nigeria, Paraguay, Philippines, Sri Lanka, Sudan, Syria,

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 15 | P a g e Date / Recipient Title Particulars /Action to be Taken Tajikistan, Tanzania, Trinidad and Tobago, Thailand, Turkey, Ukraine, Yemen, Venezuela, Vietnam, Zimbabwe and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Instruction (Number 10) repealed. 28 November 2011 FSBs Instruction (Number 15) FSBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, FSBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. In light of the particular concerns of the FATF regarding Iran and the Democratic People’s Republic of Korea (“DPRK”), FSBs were to, in addition to the requirements of the above paragraph, take appropriate measures to ensure that correspondent relationships were not being used to bypass or evade counter-measures and risk mitigation practices. The action taken by each FSB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 15) lists concerns in relation to Iran, Algeria, Angola, Argentina, Brunei Darussalam, Cambodia, DPRK, Bangladesh, Cuba, Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Ghana, Honduras, Indonesia, Kenya, Kyrgyzstan, Myanmar, Mongolia, Libya, Namibia, Nepal, Nicaragua, Nigeria, Paraguay, Philippines, Sri Lanka, Sudan, Syria, Tajikistan, Tanzania, Trinidad and Tobago, Thailand, Turkey, Ukraine, Yemen, Venezuela, Vietnam, Zimbabwe and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana).

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 16 | P a g e Date / Recipient Title Particulars /Action to be Taken Instruction (Number 13) repealed. 28 November 2011 PBs Instruction (Number 13) PBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, PBs were to ensure enhanced due diligence measures were undertaken and special attention given to all existing and new business relationships and transactions connected with such countries or territories. In light of the particular concerns of the FATF regarding Iran and the Democratic People’s Republic of Korea (“DPRK”), PBs were to, in addition to the requirements of the above paragraph, take appropriate measures to ensure that correspondent relationships were not being used to bypass or evade counter-measures and risk mitigation practices. The action taken by each PB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 15) lists concerns in relation to Iran, Algeria, Angola, Argentina, Brunei Darussalam, Cambodia, DPRK, Bangladesh, Cuba, Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Ghana, Honduras, Indonesia, Kenya, Kyrgyzstan, Myanmar, Mongolia, Libya, Namibia, Nepal, Nicaragua, Nigeria, Paraguay, Philippines, Sri Lanka, Sudan, Syria, Tajikistan, Tanzania, Trinidad and Tobago, Thailand, Turkey, Ukraine, Yemen, Venezuela, Vietnam, Zimbabwe and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Instruction (Number 11) repealed. 12 March 2012 Instruction (Number 16) FSBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, FSBs were to ensure that

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 17 | P a g e Date / Recipient Title Particulars /Action to be Taken FSBs enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. In light of the particular concerns of the FATF regarding Iran and the Democratic People’s Republic of Korea (“DPRK”), FSBs were to, in addition to the requirements of the above paragraph, take appropriate measures to ensure that correspondent relationships were not being used to bypass or evade counter-measures and risk mitigation practices. The action taken by each FSB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 16) lists concerns in relation to Iran, Algeria, Angola, Argentina, Brunei Darussalam, Cambodia, DPRK, Bangladesh, Cuba, Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Ghana, Honduras, Indonesia, Kenya, Kyrgyzstan, Myanmar, Mongolia, Libya, Namibia, Nepal, Nicaragua, Nigeria, Paraguay, Philippines, Sri Lanka, Sudan, Syria, Tajikistan, Tanzania, Trinidad and Tobago, Thailand, Turkey, Yemen, Venezuela, Vietnam, Zimbabwe and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Instruction (Number 15) repealed. 12 March 2012 PBs Instruction (Number 14) PBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, PBs were to ensure enhanced due diligence measures were undertaken and special attention given to all existing and new business relationships and transactions connected with such countries or territories. In light of the particular concerns of the FATF regarding Iran and the Democratic People’s

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 18 | P a g e Date / Recipient Title Particulars /Action to be Taken Republic of Korea (“DPRK”), PBs were to, in addition to the requirements of the above paragraph, take appropriate measures to ensure that correspondent relationships were not being used to bypass or evade counter-measures and risk mitigation practices. The action taken by each PB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 14) lists concerns in relation to Iran, Algeria, Angola, Argentina, Brunei Darussalam, Cambodia, DPRK, Bangladesh, Cuba, Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Ghana, Honduras, Indonesia, Kenya, Kyrgyzstan, Myanmar, Mongolia, Libya, Namibia, Nepal, Nicaragua, Nigeria, Paraguay, Philippines, Sri Lanka, Sudan, Syria, Tajikistan, Tanzania, Trinidad and Tobago, Thailand, Turkey, Yemen, Venezuela, Vietnam, Zimbabwe and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Instruction (Number 13) repealed. 30 October 2012 FSBs Instruction (Number 17) FSBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, FSBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. In light of the particular concerns of the FATF regarding Iran and the Democratic People’s Republic of Korea (“DPRK”), FSBs were to, in addition to the requirements of the above paragraph, take appropriate measures to ensure that correspondent relationships were not being used to bypass or evade counter-measures and risk mitigation practices.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 19 | P a g e Date / Recipient Title Particulars /Action to be Taken The action taken by each FSB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 17) lists concerns in relation to Iran, Afghanistan, Albania, Algeria, Angola, Argentina, Brunei Darussalam, Cambodia, DPRK, Bangladesh, Cuba, Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Indonesia, Kenya, Kuwait, Kyrgyzstan, Myanmar, Mongolia, Libya, Namibia, Nepal, Nicaragua, Nigeria, Philippines, Sri Lanka, Sudan, Syria, Tajikistan, Tanzania, Trinidad and Tobago, Thailand, Turkey, Yemen, Venezuela, Vietnam, Zimbabwe and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Instruction (Number 16) repealed. 30 October 2012 PBs Instruction (Number 15) PBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, PBs were to ensure enhanced due diligence measures were undertaken and special attention given to all existing and new business relationships and transactions connected with such countries or territories. In light of the particular concerns of the FATF regarding Iran and the Democratic People’s Republic of Korea (“DPRK”), PBs were to, in addition to the requirements of the above paragraph, take appropriate measures to ensure that correspondent relationships were not being used to bypass or evade counter-measures and risk mitigation practices. The action taken by each PB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Instruction (Number 15) lists concerns in relation to Iran, Afghanistan, Albania, Algeria,

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 20 | P a g e Date / Recipient Title Particulars /Action to be Taken Angola, Argentina, Brunei Darussalam, Cambodia, DPRK, Bangladesh, Cuba, Ecuador, Ethiopia, Pakistan, Turkmenistan, Sao Tomé and Principe, Antigua and Barbuda, Bolivia, Indonesia, Kenya, Kuwait, Kyrgyzstan, Myanmar, Mongolia, Libya, Namibia, Nepal, Nicaragua, Nigeria, Philippines, Sri Lanka, Sudan, Syria, Tajikistan, Tanzania, Trinidad and Tobago, Thailand, Turkey, Yemen, Venezuela, Vietnam, Zimbabwe and West Africa (Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana). Instruction (Number 14) repealed. 4 March 2013 FSBs Instruction (Number 18) Action to be taken by FSBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of the Instruction. FSBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, FSBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. In light of the particular concerns of the FATF regarding Iran and the Democratic People’s Republic of Korea (“DPRK”), FSBs were to, in addition to the requirements of the above paragraph, take appropriate measures to ensure that correspondent relationships were not being used to bypass or evade counter-measures and risk mitigation practices. The action taken by each FSB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Action was to be taken in respect of: DPRK, Ecuador, Ethiopia, Iran, Indonesia, Kenya, Myanmar, Nigeria, Pakistan, Sao Tomé and Principe, Syria, Tanzania, Turkey, Vietnam

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 21 | P a g e Date / Recipient Title Particulars /Action to be Taken and Yemen. Action to be taken by FSBs in respect of jurisdictions listed in the “Improving Global AML/CFT Compliance: On-Going Process” section of the Instruction. FSBs were to consider the risk posed by the following jurisdictions when undertaking or reviewing the assessment of risk of any business relationship or occasional transaction. The consideration of risk and of any consequential action taken by each FSB would be reviewed during on-site inspections and by other means as necessary. Action was to be taken in respect of: Afghanistan, Albania, Algeria, Angola, Antigua and Barbuda, Argentina, Bangladesh, Bolivia, Brunei Darussalam, Cuba, Cambodia, Ghana, Kuwait, Kyrgyzstan, Mongolia, Morocco, Namibia, Nepal, Nicaragua, Philippines, Sri Lanka, Sudan, Tajikistan, Thailand, Venezuela, and Zimbabwe. Action to be taken FSBs in respect of jurisdictions which are of concern to the Commission. FSBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this instruction. Additionally, FSBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. Action taken by each FSBs under this instruction would be reviewed during on-site inspections and by other means as necessary. Action was to be taken in respect of: Libya, Venezuela, West Africa ((Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana)

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 22 | P a g e Date / Recipient Title Particulars /Action to be Taken Instruction (Number 17) repealed. 4 March 2013 PBs Instruction (Number 16) Action to be taken by PBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of the Instruction. PBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this instruction. Additionally, PBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. In light of the particular concerns of the FATF regarding Iran and the Democratic People’s Republic of Korea (“DPRK”), PBs were to, in addition to the requirements of the above paragraph, take appropriate measures to ensure that correspondent relationships were not being used to bypass or evade counter-measures and risk mitigation practices. The action taken by each PB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Action was to be taken in respect of: DPRK, Ecuador, Ethiopia, Iran, Indonesia, Kenya, Myanmar, Nigeria, Pakistan, Sao Tomé and Principe, Syria, Tanzania, Turkey, Vietnam and Yemen. Action to be taken by PBs in respect of jurisdictions listed in the “Improving Global AML/CFT Compliance: On-Going Process” section of the Instruction. PBs were to consider the risk posed by the following jurisdictions when undertaking or reviewing the assessment of risk of any business relationship or occasional transaction. The

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 23 | P a g e Date / Recipient Title Particulars /Action to be Taken consideration of risk and of any consequential action taken by each PB would be reviewed during on-site inspections and by other means as necessary. Action was to be taken in respect of: Afghanistan, Albania, Algeria, Angola, Antigua and Barbuda, Argentina, Bangladesh, Bolivia, Brunei Darussalam, Cuba, Cambodia, Ghana, Kuwait, Kyrgyzstan, Mongolia, Morocco, Namibia, Nepal, Nicaragua, Philippines, Sri Lanka, Sudan, Tajikistan, Thailand, Venezuela, and Zimbabwe. Action to be taken PBs in respect of jurisdictions which are of concern to the Commission. PBs were to exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, PBs were to ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories. Action taken by each PB under this Instruction would be reviewed during on-site inspections and by other means as necessary. Action was to be taken in respect of: Libya, Venezuela, West Africa ((Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana) Instruction (Number 15) repealed. 27 June 2013 FSBs Instruction (Number 19) Action to be taken by FSBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of this Instruction. FSBs must exercise a greater degree of caution when taking on business from the countries

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 24 | P a g e Date / Recipient Title Particulars /Action to be Taken or territories specified in this Instruction. Additionally, FSBs must ensure that enhanced due diligence measures are undertaken and special attention given to all business relationships and transactions connected with such countries or territories. In light of the particular concerns of the FATF regarding Iran and the Democratic People’s Republic of Korea (“DPRK”), FSBs are to, in addition to the requirements of the above paragraph, take appropriate measures to ensure that correspondent relationships are not being used to bypass or evade counter-measures and risk mitigation practices. The action taken by each FSB under this Instruction will be reviewed during on-site inspections and by other means as necessary. Action is to be taken in respect of: DPRK, Ecuador, Ethiopia, Iran, Indonesia, Kenya, Myanmar, Nigeria, Pakistan, Sao Tomé and Principe, Syria, Tanzania, Turkey, Vietnam and Yemen. Action to be taken by FSBs in respect of jurisdictions listed in the “Improving Global AML/CFT Compliance: On-Going Process” section of this Instruction. FSBs are to consider the risk posed by the following jurisdictions when undertaking or reviewing the assessment of risk of any business relationship or occasional transaction. The consideration of risk and of any consequential action taken by each FSB will be reviewed during on-site inspections and by other means as necessary. Action is to be taken in respect of: Afghanistan, Albania, Algeria, Angola, Antigua and Barbuda, Argentina, Bangladesh, Bolivia, Brunei Darussalam, Cambodia, Cuba, Ghana, Kuwait, Kyrgyzstan, Laos PDR, Mongolia, Morocco, Namibia, Nepal, Nicaragua, Nigeria, Philippines, Sri Lanka, Sudan, Tajikistan, Thailand, Venezuela, and Zimbabwe.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 25 | P a g e Date / Recipient Title Particulars /Action to be Taken Action to be taken FSBs in respect of jurisdictions which are of concern to the Commission. FSBs must exercise a greater degree of caution when taking on business from the countries or territories specified in this instruction. Additionally, FSBs must ensure that enhanced due diligence measures are undertaken and special attention given to all business relationships and transactions connected with such countries or territories. Action taken by each FSB under this Instruction will be reviewed during on-site inspections and by other means as necessary. Action is to be taken in respect of: Libya, Venezuela, West Africa ((Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana) Instruction (Number 18) repealed. 27 June 2013 PBs Instruction (Number 17) Action to be taken by PBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of this Instruction. PBs must exercise a greater degree of caution when taking on business from the countries or territories specified in this Instruction. Additionally, PBs must ensure that enhanced due diligence measures are undertaken and special attention given to all business relationships and transactions connected with such countries or territories. In light of the particular concerns of the FATF regarding Iran and the Democratic People’s Republic of Korea (“DPRK”), PBs are to, in addition to the requirements of the above paragraph, take appropriate measures to ensure that correspondent relationships are not

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 26 | P a g e Date / Recipient Title Particulars /Action to be Taken being used to bypass or evade counter-measures and risk mitigation practices. The action taken by each PB under this Instruction will be reviewed during on-site inspections and by other means as necessary. Action is to be taken in respect of: DPRK, Ecuador, Ethiopia, Iran, Indonesia, Kenya, Myanmar, Nigeria, Pakistan, Sao Tomé and Principe, Syria, Tanzania, Turkey, Vietnam and Yemen. Action to be taken by PBs in respect of jurisdictions listed in the “Improving Global AML/CFT Compliance: On-Going Process” section of this Instruction. PBs are to consider the risk posed by the following jurisdictions when undertaking or reviewing the assessment of risk of any business relationship or occasional transaction. The consideration of risk and of any consequential action taken by each PB will be reviewed during on-site inspections and by other means as necessary. Action is to be taken in respect of: Afghanistan, Albania, Algeria, Angola, Antigua and Barbuda, Argentina, Bangladesh, Bolivia, Brunei Darussalam, Cambodia, Cuba, Ghana, Kuwait, Kyrgyzstan, Laos PDR, Mongolia, Morocco, Namibia, Nepal, Nicaragua, Nigeria, Philippines, Sri Lanka, Sudan, Tajikistan, Thailand, Venezuela, and Zimbabwe. Action to be taken PBs in respect of jurisdictions which are of concern to the Commission. PBs must exercise a greater degree of caution when taking on business from the countries or territories specified in this instruction. Additionally, PBs must ensure that enhanced due diligence measures were undertaken and special attention given to all business relationships and transactions connected with such countries or territories.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 27 | P a g e Date / Recipient Title Particulars /Action to be Taken Action taken by each PB under this Instruction will be reviewed during on-site inspections and by other means as necessary. Action is to be taken in respect of: Libya, Venezuela, West Africa ((Morocco, Mauritania, Senegal, Cape Verde Islands, Guinea-Bissau, Guinea, Sierra Leone, Liberia, Ivory Coast, Ghana) Instruction (Number 16) repealed.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 28 | P a g e 15 November 2013 Instruction (Number 20) Action to be taken by FSBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of this Instruction. Action to be taken by FSBs in respect of jurisdictions listed in the “Improving Global AML/CFT Compliance: On-Going Process” section of this Instruction. Action to be taken FSBs in respect of jurisdictions which are of concern to the Commission. Instruction (Number 19) repealed. 15 November 2013 Instruction (Number 18) Action to be taken by PBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of this Instruction. Action to be taken by PBs in respect of jurisdictions listed in the “Improving Global AML/CFT Compliance: On-Going Process” section of this Instruction. Action to be taken PBs in respect of jurisdictions which are of concern to the Commission. Instruction (Number 17) repealed.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 29 | P a g e 26 February 2014 Instruction (Number 21) Action to be taken by FSBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of this Instruction. The FATF Public Statement  Kenya & Tanzania moved to Improving global AML/CFT compliance; on- going process due to their progress in substantially addressing their action plan agreed with the FATF. Improving Global AML/CFT Compliance: On-Going Process section of this Instruction.  Mongolia, Papua New Guinea & Uganda added. Jurisdictions no longer subject to the FATF’s on-going global AML/CFT compliance process  Antigua & Barbuda, Bangladesh, & Vietnam Action to be taken by FSBs & PBs in respect of jurisdictions which are of concern to the Commission  No change Jurisdictions not making sufficient progress  Afghanistan and Cambodia added. Other Action  FSB Instruction (Number 20) repealed. 26 February 2014 Instruction (Number 19) Action to be taken by PBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of this Instruction. The FATF Public Statement  Kenya & Tanzania moved to Improving global AML/CFT compliance; on- going process due to their progress in substantially addressing their action plan agreed with the FATF. Improving Global AML/CFT Compliance: On-Going Process section of this Instruction.  Mongolia, Papua New Guinea & Uganda added. Jurisdictions no longer subject to the FATF’s on-going global AML/CFT compliance process  Antigua & Barbuda, Bangladesh, & Vietnam Action to be taken by FSBs & PBs in respect of jurisdictions which are of concern to the Commission  No change Jurisdictions not making sufficient progress  Afghanistan and Cambodia added. Other Action PB Instruction (Number 18) repealed.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 30 | P a g e 3 June 2014 Instruction M 01/2014 Action to be taken by FSBs in Respect of Jurisdictions Listed in this Instruction. Financial services businesses must ensure enhanced client due diligence measures are undertaken and special attention given to all existing and new business relationships and transactions connected with Bosnia and Herzegovina. 3 June 2014 Instruction M 01/2014 Action to be taken by PBs in Respect of Jurisdictions Listed in this Instruction. Prescribed businesses must ensure enhanced client due diligence measures are undertaken and special attention given to all existing and new business relationships and transactions connected with Bosnia and Herzegovina.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 31 | P a g e 9 July 2014 Instruction 02/2014 Action to be taken by FSBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of this Instruction. The FATF Public Statement Ethiopia, Pakistan, Syria, Turkey and Yemen are now included in Improving Global AML/CFT Compliance: On-going Process” Kenya, Kyrgyzstan, Mongolia, Nepal and Tanzania are no longer subject to the FATF’s on-going global AML/CFT compliance process Other Action FSB Instruction (Number 21) repealed. 9 July 2014 Instruction 02/2014 Action to be taken by PBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of this Instruction. The FATF Public Statement Ethiopia, Pakistan, Syria, Turkey and Yemen are now included in Improving Global AML/CFT Compliance: On-going Process” Kenya, Kyrgyzstan, Mongolia, Nepal and Tanzania are no longer subject to the FATF’s on-going global AML/CFT compliance process Other Action PB Instruction (Number 19) repealed. 1 August 2014 Instruction 03/2014 Action to be taken by Financial Services Businesses The Commission requires the Board of each financial services business to:
a) review business compliance arrangements against the requirements of this Instruction; b) review and revise policies, procedures and controls in accordance with the legislative obligations of the legislation; c) replace existing copies of Chapter 14 of the Handbook with the revised Chapter attached to the Instruction and published on the Commission’s website; and d) delete Appendix L of the Handbook. When undertaking the review Boards must note that, in accordance with paragraph 30 of the Handbook, a financial services business must ensure that the Commission is advised of any material failure to comply with the provisions of the Regulations and the rules in the Handbook and of any serious breaches of the policies, procedures or controls of the financial services business.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 32 | P a g e Instruction 03/2014 22 August 2014 Instruction 04/2014 Action to be taken by Financial Service Businesses The Commission requires the Board, or equivalent, of each financial service business, by no later than close of business 5 September 2014 to:
a) Replace existing hard copies of Chapter 10 of the Handbook with the revised version of Chapter 10 attached to this Instruction. b) Replace existing hard copies of Appendix D2 of the Handbook with the revised version of Appendix D2 attached to this Instruction. c) Replace any electronic copies of the Handbook with the revised version which can be accessed on the Commission’s website. d) Take steps to ensure that the business’ policies, procedures and controls concerning the reporting of suspicious activity and the forms used to report suspicious activity to the FIS, are updated to incorporate the amendments. When undertaking the review Boards must note that, in accordance with paragraph 30 of the Handbook, a financial service business must ensure that the Commission is advised of any material failure to comply with the provisions of the Regulations and the rules in the Handbook and of any serious breaches of the policies, procedures or controls of the financial service business. 22 August 2014 Instruction 04/2014 Action to be taken by Prescribed Businesses The Commission requires the Board, or equivalent, of each prescribed business, by no later than close of business 5 September 2014 to:
a) Replace existing hard copies of Chapter 8 of the Handbook with the revised version of Chapter 8 attached to this Instruction. b) Replace existing hard copies of Appendix D2 of the Handbook with the revised version of Appendix D2 attached to this Instruction. c) Replace any electronic copies of the Handbook with the revised version which can be accessed on the Commission’s website. d) Take steps to ensure that the business’ policies, procedures and controls concerning the reporting of suspicious activity and the forms used to report suspicious activity to the FIS, are updated to incorporate the amendments.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 33 | P a g e 7 October 2014 Instruction 05/2014 Instruction issued in light of a revised public statement on Bosnia and Herzegovina adopted by the Council of Europe Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) for States and territories evaluated by MONEYVAL at its 45th plenary meeting (15 – 19 September 2014). Action to be taken by financial services businesses in respect of the MONEYVAL public statement. Financial services businesses must ensure enhanced client due diligence measures are undertaken and special attention given to all existing and new business relationships and transactions connected with Bosnia and Herzegovina. Financial services businesses must exercise a greater degree of caution and apply controls and measures as required in Regulation 5. 7 October 2014 Instruction 05/2014 Instruction issued in light of a revised public statement on Bosnia and Herzegovina adopted by the Council of Europe Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) for States and territories evaluated by MONEYVAL at its 45th plenary meeting (15 – 19 September 2014). Action to be taken by prescribed businesses in respect of the MONEYVAL public statement. Prescribed businesses must ensure enhanced client due diligence measures are undertaken and special attention given to all existing and new business relationships and transactions connected with Bosnia and Herzegovina. Prescribed businesses must exercise a greater degree of caution and apply controls and measures as required in Regulation 5.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 34 | P a g e 14 November 2014 Instruction 06/2014 Action to be taken by FSBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of this Instruction. The FATF Public Statement Guyana has been added to the “Improving Global AML/CFT Compliance: On-going Process” Argentina, Cuba, Ethiopia, Tajikistan and Turkey are no longer subject to the FATF’s on-going global AML/CFT compliance process Other Action FSB Instruction (Number 02/2014) repealed. Libya has been removed from section C of the Instruction. 14 November 2014 Instruction 06/2014 Action to be taken by PBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of this Instruction. The FATF Public Statement Guyana has been added to the “Improving Global AML/CFT Compliance: On-going Process” Argentina, Cuba, Ethiopia, Tajikistan and Turkey are no longer subject to the FATF’s on-going global AML/CFT compliance process Other Action PB Instruction (Number 02/2014) repealed. Libya has been removed from section C of the Instruction.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 35 | P a g e 18 December 2014 Instruction 07/2014 Instruction issued in light of a revised public statement on Bosnia and Herzegovina adopted by the Council of Europe Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) for states and territories evaluated by MONEYVAL at its 46th plenary meeting (8 – 12 December 2014). Action to be taken by financial services businesses in respect of the MONEYVAL public statement. Financial services businesses must ensure enhanced client due diligence measures are undertaken and special attention given to all existing and new business relationships and transactions connected with Bosnia and Herzegovina. Financial services businesses must exercise a greater degree of caution and apply controls and measures as required in Regulation 5. 18 December 2014 Instruction 07/2014 Instruction issued in light of a revised public statement on Bosnia and Herzegovina adopted by the Council of Europe Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) for states and territories evaluated by MONEYVAL at its 46 th plenary meeting (8 – 12 December 2014). Action to be taken by prescribed businesses in respect of the MONEYVAL public statement. Prescribed businesses must ensure enhanced client due diligence measures are undertaken and special attention given to all existing and new business relationships and transactions connected with Bosnia and Herzegovina. Prescribed businesses must exercise a greater degree of caution and apply controls and measures as required in Regulation 5.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 36 | P a g e 25 March 2015 Instruction 01/2015 Action to be taken by FSBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of this Instruction. The FATF Public Statement Indonesia has been added to the “Improving Global AML/CFT Compliance: On-going Process” Albania, Cambodia, Kuwait, Namibia, Nicaragua, Pakistan and Zimbabwe are no longer subject to the FATF’s on￾going global AML/CFT compliance process Other Action FSB Instruction (Number 06/2014) repealed. 25 March 2015 Instruction 01/2015 Action to be taken by PBs in Respect of Jurisdictions Listed in the “The FATF Public Statement” section of this Instruction. The FATF Public Statement Indonesia has been added to the “Improving Global AML/CFT Compliance: On-going Process” Albania, Cambodia, Kuwait, Namibia, Nicaragua, Pakistan and Zimbabwe are no longer subject to the FATF’s on￾going global AML/CFT compliance process Other Action PB Instruction (Number 06/2014) repealed.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 37 | P a g e 15 May 2015 Instruction 02/2015 Instruction issued in light of a revised public statement on Bosnia and Herzegovina adopted by the Council of Europe Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) for States and territories evaluated by MONEYVAL at its 47th plenary meeting (14 – 17 April 2015). Action to be taken by financial services businesses in respect of the MONEYVAL public statement. Financial services businesses must ensure enhanced client due diligence measures are undertaken and special attention given to all existing and new business relationships and transactions connected with Bosnia and Herzegovina. Financial services businesses must exercise a greater degree of caution and apply controls and measures as required in Regulation 5. 15 May 2015 Instruction 02/2015 Instruction issued in light of a revised public statement on Bosnia and Herzegovina adopted by the Council of Europe Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) for States and territories evaluated by MONEYVAL at its 47th plenary meeting (14 – 17 April 2015). Action to be taken by prescribed businesses in respect of the MONEYVAL public statement. Prescribed businesses must ensure enhanced client due diligence measures are undertaken and special attention given to all existing and new business relationships and transactions connected with Bosnia and Herzegovina. Prescribed businesses must exercise a greater degree of caution and apply controls and measures as required in Regulation 5.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 38 | P a g e 16 July 2015 Instruction 03/2015 FSB Instruction (Number 01/2015) repealed. High-risk and non-cooperative Jurisdictions Ecuador removed Improving Global AML/CFT Compliance: on-going process. Indonesia removed Iraq removed Bosnia & Herzegovina added Ecuador added Uganda added Jurisdictions not making sufficient progress Iraq Jurisdictions no longer subject to monitoring Indonesia

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 39 | P a g e 16 July 2015 Instruction 03/2015 PB Instruction (Number 01/2015) repealed. High-risk and non-cooperative Jurisdictions Ecuador removed Improving Global AML/CFT Compliance: on-going process. Indonesia removed Iraq removed Bosnia & Herzegovina added Ecuador added Uganda added Jurisdictions not making sufficient progress Iraq Jurisdictions no longer subject to monitoring Indonesia

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 40 | P a g e 2 October 2015 Repeal of Business from Sensitive Sources, Bosnia & Herzegovina On the 18 September 2015, the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism (MONEYVAL) issued an updated public statement in respect of Bosnia & Herzegovina. The statement confirmed that MONEYVAL was satisfied that sufficient changes had been made to its AML/CFT legislation to merit removal of its request to members that their financial institutions apply enhanced due diligence to business connected to Bosnia and Herzegovina. The Commission is therefore repealing instructions numbered, M 01/2014, 05/2014, 07/2014 & 02/2015 FSB & PB M01/2014, 05/2014, 07/2014 & 02/2015 are repealed.

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 41 | P a g e 19 November 2015 Instruction 04/2015 FSB Instruction (Number 03/2015) repealed. High-risk and non-cooperative Jurisdictions Algeria removed Improving Global AML/CFT Compliance: on-going process. Algeria added Ecuador removed Iraq added Lao PDR removed Sudan removed Jurisdictions not making sufficient progress Iraq removed Lao PDR added Jurisdictions no longer subject to monitoring Ecuador Sudan

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 42 | P a g e 19 November 2015 Instruction 04/2015 PB Instruction (Number 03/2015) repealed. High-risk and non-cooperative Jurisdictions Algeria removed Improving Global AML/CFT Compliance: on-going process. Algeria added Ecuador removed Iraq added Lao PDR removed Sudan removed Jurisdictions not making sufficient progress Iraq removed Lao PDR added Jurisdictions no longer subject to monitoring Ecuador Sudan

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 43 | P a g e 22 March 2016 Instruction 01/2016 FSB and PB Instructions (Number 04/2015) repealed. High-risk and non-cooperative Jurisdictions Myanmar removed Improving Global AML/CFT Compliance: on-going process. Myanmar added Lao PDR added Vanuatu added Jurisdictions not making sufficient progress Lao PDR removed Jurisdictions no longer subject to monitoring Algeria Angola Panama

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 44 | P a g e 1 August 2016 Instruction 02/2016 FSB and PB Instructions (Number 01/2016) repealed. High-risk and non-cooperative Jurisdictions N/A Improving Global AML/CFT Compliance: on-going process. N/A Jurisdictions not making sufficient progress N/A Jurisdictions no longer subject to monitoring Myanmar Papua New Guinea

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 45 | P a g e 25 January 2017 Instruction 01/2017 FSB and PB Instructions (Number 02/2016) repealed. High-risk and non-cooperative Jurisdictions N/A Improving Global AML/CFT Compliance: on-going process N/A Jurisdictions not making sufficient progress N/A Jurisdictions no longer subject to monitoring Guyana Jurisdictions of concern to the Guernsey Financial Services Commission Haiti added Nigeria added

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 46 | P a g e 10 April 2017 Instruction 02/2017 FSB and PB Instructions (Number 02/2016) repealed. High-risk and non-cooperative Jurisdictions N/A Improving Global AML/CFT Compliance: on-going process Ethiopia added Jurisdictions not making sufficient progress N/A Jurisdictions no longer subject to monitoring N/A Jurisdictions of concern to the Guernsey Financial Services Commission N/A

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 47 | P a g e 20 July 2017 Instruction 03/2017 FSB and PB Instructions (Number 02/2017) repealed. High-risk and non-cooperative Jurisdictions N/A Improving Global AML/CFT Compliance: on-going process N/A Jurisdictions not making sufficient progress N/A Jurisdictions no longer subject to monitoring Afghanistan removed Lao PDR removed Jurisdictions of concern to the Guernsey Financial Services Commission N/A

Instructions and Notices Issued by the Guernsey Financial Services Commission Business From Sensitive Sources December 2007 – Present Last Updated: 5 December 2017 48 | P a g e 5 December 2017 Instruction 04/2017 FSB and PB Instructions (Number 03/2017) repealed. High-risk and non-cooperative Jurisdictions N/A Improving Global AML/CFT Compliance: on-going process Sri Lanka added Trinidad and Tobago added Tunisia added Jurisdictions not making sufficient progress N/A Jurisdictions no longer subject to monitoring Uganda removed Jurisdictions of concern to the Guernsey Financial Services Commission N/A