The island’s financial regulator had pledged to review its due diligence and other operating requirements after some banks began abruptly withdrawing certain services from non-finance Guernsey businesses last some, citing regulatory obstacles as the reason.

But it has now concluded that the difficulties faced by some firms were not because of increased or new regulation by the GFSC. 

While it says guidance for pooled accounts today is no more stringent that the past several years, its decided to update guidance in its Financial Crime Handbook after consulting with local industry and banks to clear up any confusion. 

The risk level of money laundering through pooled client accounts has now been reduced for certain sectors.  

While there was not an existing local regulatory impediment, we extended the definition of who a bank can treat as a customer in a pooled bank account arrangement, providing the bank has assessed the proposed relationship as low risk, to include businesses such as Bailiwick-based non-financial professional businesses servicing the local economy such as property management, auction sales and payroll,” it said. 


In making this change we paid close regard to the findings from the Bailiwick’s latest National Risk Assessment that the risk of money laundering from domestic proceeds generating crime was low and where laundering from domestic criminality did occur proceeds were likely to be cash-based and relatively small.  

The review came after pressure was applied to institutions by the Guernsey Chamber of Commerce who raised the alarm in July that some of its member businesses were experiencing sudden withdrawal of banking services, while also highlighting the long-winded process to set up other services.   

The GFSC says it will continue to work with firms on the new guidance, which it hopes will reduce burdens on the banks and businesses.  

It had previously told banks that its practices were “unacceptable”.