With Guernsey’s new anti-money laundering regime set to come into effect at the end of this month, Babbé Managing Partner Andrew Laws says that while the transitional provisions appear generous, organisations must act without delay. Here, he shares his top 10 tips on actions to be taken.
Firms must:
1. Understand their money laundering and terrorist financing risks
2. Consider carefully Guernsey’s National Risk Assessment (once it is 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
Babbé’s full analysis of the changes and recommendations that the new AML handbook sets out can be found here