The Anguilla Financial Services Commission published a summary of findings from a themed inspection of micro-lenders covering April 2024 to March 2025, assessing customer onboarding, customer due diligence and related AML/CFT policies and procedures. The review identified recurring weaknesses in the completeness and quality of customer files and in evidencing due diligence activity. Six micro-lender businesses were inspected. The Commission requested each firm’s most recent AML/CFT policies and procedures manual and a full customer list from January 2019 to the then-current period, and tested customer files across five areas including onboarding forms, identification, proof of address, source of income/funds, and due diligence searches and checks. Observed issues included missing or incomplete loan application forms (including unsigned or poor-quality copies), illegible or expired identification documents and, for some firms, the absence of an Anguillan residency stamp in passports where firms’ own policies required borrowers to be residents or Belongers. Some service providers were deemed grossly deficient in collecting proof of address, and where collected, documents could be outdated against firms’ stated three-month validity standard. Source of income/funds evidence was sometimes older than three months at application and there was no evidence of ongoing updates, while the majority of firms did not retain due diligence search results on file even where checks may have been performed. The Commission indicated it intends to conduct a more focused review of service providers identified as having major deficiencies. It also noted that compliance levels inform whether non-regulated service providers can maintain registration, and that failures to comply with applicable AML/CFT legislation may lead to enforcement action.

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