GFSC Thematic Review of ML and TF Business Risk Assessments [15th December 2022]
31/12/2022
The GFSC issued its report on the thematic review of business risk assessments ON money laundering and terrorist financing
The thematic was undertaken to assess more than 100 licensed and registered firms [across all sectors] and how well firms identified and assessed these risks to their businesses.
The results were positive, demonstrating that most Business Risk Assessments met Bailiwick's regulatory requirements.
A copy of the thematic review is here.
- https://www.gfsc.gg/sites/default/files/2022-12/20221215%20-%20ML%20TF%20BRA%20Thematic%20Review.pdf
The GFSC noted many examples of good practice during our review.
Nevertheless, seven areas for improvement were identified where firms could improve their risk assessments, of which there were two key areas.
- Firstly, firms could benefit from additional research and using the National Risk Assessment to help them improve upon identifying the terrorist financing risks relevant to their businesses through their
- customers;
- jurisdictions;
- products;
- services;
- transactions and
- delivery channels.
- Secondly, firms are advised to make more use of their management information to ensure that the assessments are relevant and tailored to the business.
The GFSC will be holding an industry event in 2023 to discuss the findings, and Invitations will be sent out in due course.
In the meantime, all firms are encouraged to consider the report's contents, particularly when updating and revising their business risk assessments.
https://www.gfsc.gg/sites/default/files/2022-12/20221215%20-%20ML%20TF%20BRA%20Thematic%20Review.pdf
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.