Thematic Review on Reporting Suspicion
The Guernsey Financial Services Commission have released their thematic review on reporting suspicion. The review covered both financial services and prescribed businesses and was undertaken during the second half of 2020. All firms which took part in this industry-wide review had appointed a money laundering reporting officer (“MLRO”) and had policies and procedures for the reporting of suspicion, which provide guidance to their staff on forming a suspicion and what to do.
This thematic review was undertaken in Guernsey, as such there will be framework and policy differences when compared to Manx legislation. However the findings contained within this report may also be useful to Isle of Man firms.
The GFSC found in their review that the majority of firms reviewed, the policies and/or procedures did not cast a full framework over the reporting process or provide comprehensive guidance for the MLRO and nominated officer on the firm’s expectations on the fulfilment of their roles.
The GFSC highlight that the boards are ultimately responsible for ensuring that their firms comply with the AML/CFT regulatory framework including ensuring that the policies, procedures and controls for the reporting of suspicion are fit for purpose and that staff are sufficiently skilled to discharge this important responsibility. This area was not generally on boards’ radar when they were considering the effectiveness of their AML/CFT controls.
Link the the thematic review