The Gibraltar Financial Services Commission (“GFSC”) recently held a Trust & Company Service Provider (“TCSP”) Seminar to highlight the specific trends across the industry identified during the recent Thematic Reviews in comparison to those carried out by them in 2017.

What were the issues in 2017?

The main issues highlighted by the GFSC in 2017 were in relation to the following areas:

  • Customer Due Diligence
  • Ongoing Monitoring, and
  • Transaction Monitoring

What current issues are still being highlighted?

In general Firms do have adequate policies and procedures in place, however they have identified deficiencies in the application of these.

After this last round of Thematic Reviews the GFSC has identified that firms are failing to meet the requirements in the follow areas:

  • Source of Wealth / Funds
  • Ongoing Monitoring / Transaction Monitoring
  • Risk Assessment
  • Independent Audit
  • Training

The seminar included an analysis by the GFSC of their finding verses the requirements / expectations in each of the areas identified above and concluded with a number of case studies again highlighting the issues listed above.

How has the industry adapted so far?

There have been changes in relevant legislation since then and, to help firms implement these changes the GFSC has since published additional guidance in respect of Source of wealth / funds, risk assessments and transaction monitoring.

How can TAG Consultancy help?

TAG Consultancy specialise in Compliance services. This means the review of compliance systems and processes, conducting AML Audits, AML Training, the drafting and review of policies and outsourcing its staff for daily compliance needs such as onboarding and file reviews.
If you require support with any of your compliance and AML requirements, you may contact us here and we will do our best to assist!

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