Managing Partner Andrew Laws said while the transitional provisions appear generous, organisations must act without delay.
He has shared his top ten tips on actions to be taken by local firms:
1. Understand their money laundering and terrorist financing risks
2. Carefully consider Guernsey’s National Risk Assessment once it has been published
3. Prepare separate Business Risk Assessments for money laundering and terrorist financing
4. Determine and document their Risk Appetite and communicate this effectively to staff
5. Appoint the right individuals to the key roles of Money Laundering Reporting Officer, Money Laundering Compliance Officer and Nominated Officer
6. Understand the requirements in respect of beneficial owners of companies and trusts
7. Appreciate what is meant by ‘Enhanced Measures’
8. Identify the different categories of PEP and undertake due diligence in relation to them accordingly
9. Read the new handbook carefully
10. Act now, don’t delay
The company’s full analysis of the changes and recommendations that the new AML handbook sets out can be found here.
Pictured top: Andrew Laws.