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Customer Due Diligence

Framework Overview

Timing

Failure to Complete Customer Due Diligence

Identifying Natural Persons

Verifying Natural Persons

Identification Data for Verification

Verification of Address

Independent Data Sources

Identification Data Considerations

Legal Persons and Legal Arrangements

Identifying Legal Persons

Verifying Legal Persons

Transparent Legal Persons

Legal Bodies Listed on a Recognised Stock Exchange

Foundations

Verifying Foundations

Control of a Foundation

Trusts and Other Legal Arrangements

Beneficial Owners of a Trust

Certification

Suitable Certifier

Certification of Legal Entity Documents

Enhanced Measures

Enhanced Customer Due Diligence

Bearer Shares

Source of Funds and Wealth

Politically Exposed Persons

Family Members and Close Associates

PEP Declassification Periods

Monitoring Transactions and Activity

Red Flags

Real-Time vs. Post-Event Monitoring

Examination

On-going Customer Due Diligence

Record Keeping

Beneficial Ownership of Guernsey and Alderney Legal Persons

Thematic Review – 2018 / 2019

Executive Summary

Tier 1 - Identifying any natural person who controls the legal person through ownership

Tier 2 - Identifying any natural person who controls the legal person through other means

Tier 3 - Where no such natural persons can be identified in either of tiers 1 and 2

Key Findings: Identifying and Verifying Beneficial Ownership

Case Studies on Beneficial Owners

Key Findings: Systems and Controls

Source of Funds / Source of Wealth in the Private Wealth Management Sector

Thematic Review – 2019

Regulatory Requirements

Establishing and Understanding Source of Wealth and Funds

Gathering Information from the Customer

Applying a Risk Based Approach to Corroborating SOW and SOF

PEP Relationships

Sources of Corroborating SOW and SOF

A Sense Check

Reviewing SOW and SOF

Reporting Suspicion

Thematic Review – 2020

Regulatory requirements

Section One - Board oversight and MLRO capabilities and capacity

Knowledge, skill and experience of MLRO and MLCO

Capacity, resources and independence of MLRO and MLCO

Policies, procedures and controls

Management Information ("MI") of Suspicious Activity Reporting

Review of compliance with the AML/CFT regulatory framework

Training

Section Two - Effectiveness of SAR policies, procedures and controls

Internal suspicious activity thresholds

Timeliness of suspicious activity reports

Internal record keeping and controls

Information to be provided to the FIS

FIS requests for additional information

Tipping off

Artemis Trustees Limited

Relevant Legislation

The Licensee failed to carry out ongoing and effective monitoring of clients

The Licensee failed to take reasonable measures to establish source of funds and source of wealth for high-risk customers

The Licensee failed to regularly review its customer risk assessments and ensure all relevant risk factors were considered

The Licensee failed to take measures to understand the ownership and control of customers

The Licensee failed to establish and maintain appropriate and effective procedures and controls to ensure compliance with requirements to make disclosures

Aggravating Factors

Mitigating Factors

ITI Trade LTD. (in Administration Management) and Mr Alex Phil

The Licensee failed to properly conduct relationship risk assessments, taking into account relevant high-risk factors and to regularly review relationship risk assessments

The Licensee failed to take reasonable measures to identify if a customer is acting on behalf of another person and identify and verify the identity of that person

The Licensee failed to carry out Customer Due Diligence ("CDD") and Enhanced Customer Due Diligence ("ECDD")

The Licensee failed to identify PEPs

The Licensee failed to monitor transactions and activity

The Licensee failed to ensure appropriate and effective AML/CFT policies, procedures and controls

Corporate governance failings and failure to comply with the COB Rules, the Code of Corporate Governance and the Principles of Conduct of Finance Business

Aggravating factors

Mitigating factors

Quiz

Survey/Feedback

Welcome to the comprehensive course on "Due Diligence and Financial Crime Controls in Guernsey. " In today's highly regulated financial landscape, understanding and implementing robust Customer Due Diligence (CDD) and Anti-Money Laundering (AML) frameworks is critical for professionals in the finance and wealth management sectors.

Welcome to the comprehensive course on "Due Diligence and Financial Crime Controls in Guernsey." In today's highly regulated financial landscape, understanding and implementing robust Customer Due Diligence (CDD) and Anti-Money Laundering (AML) frameworks is critical for professionals in the finance and wealth management sectors. This course provides an in-depth exploration of the regulatory requirements and best practices specific to Guernsey and Alderney.

Throughout this course, you will dive deep into the intricacies of identifying and verifying natural and legal persons, understanding beneficial ownership, and navigating the complexities of trusts, foundations, and transparent legal entities. We will cover essential topics such as Enhanced Customer Due Diligence (ECDD), managing Politically Exposed Persons (PEPs), and establishing the Source of Funds (SOF) and Source of Wealth (SOW) in the private wealth management sector.

Furthermore, the curriculum includes detailed thematic reviews from recent years, offering practical insights into reporting suspicions, managing internal thresholds, and avoiding tipping off. Real-world case studies, including Artemis Trustees Limited and ITI Trade LTD, will highlight the consequences of compliance failures and the importance of effective corporate governance. By the end of this course, you will be equipped with the knowledge to conduct ongoing monitoring, recognize red flags, and ensure your organization's policies align with the latest legal and regulatory standards in Guernsey. Join us to strengthen your expertise in financial crime controls and safeguard your institution against regulatory risks.

Due Diligence and Financial Crime Controls in Guernsey

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            <p>Operating within the Guernsey financial services sector requires a rigorous commitment to mitigating financial crime risks and adhering to stringent regulatory frameworks. This comprehensive course is designed specifically for financial services providers in the Bailiwick of Guernsey, offering an in-depth examination of the essential controls required to prevent money laundering, terrorist financing, and proliferation financing. Participants will explore the foundational and advanced elements of Customer Due Diligence (CDD), including the precise identification and verification of natural persons, legal entities, transparent legal persons, trusts, and foundations. Furthermore, the curriculum addresses the complexities surrounding Politically Exposed Persons (PEPs), the application of Enhanced Customer Due Diligence (ECDD), and the critical processes involved in ongoing transaction monitoring, independent data sourcing, and meticulous record-keeping.</p>

<p>Beyond the core CDD framework, this program delves into the specific findings of recent thematic reviews conducted within the jurisdiction. Professionals will gain critical insights into the transparency of beneficial ownership for Guernsey and Alderney legal persons, as well as the rigorous requirements for establishing and corroborating Source of Funds (SOF) and Source of Wealth (SOW) within the private wealth management sector. The course also meticulously outlines the protocols for reporting suspicion, emphasizing the roles, capabilities, and independence of the MLRO and MLCO, alongside the effectiveness of Suspicious Activity Reporting (SAR) procedures and the prevention of tipping off. To contextualize these regulatory obligations, the syllabus includes detailed analyses of recent enforcement actions, specifically examining the compliance failings of Artemis Trustees Limited and ITI Trade LTD. By analyzing these real-world case studies and the resulting disciplinary measures, practitioners will be better equipped to implement robust, risk-based compliance frameworks that safeguard their institutions and uphold the integrity of Guernsey's financial center.</p>
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