The Guernsey Financial Services Commission has issued a thematic review report assessing how effectively investment firms monitor and comply with the intermediary and correspondent relationship requirements in its Handbook on Countering Financial Crime (AML/CFT/CPF). The review found that most firms had a good understanding of the risks in these relationships and had appropriate controls, but it also set out six areas for improvement relevant to all firms using intermediaries or correspondents. Work included 30 onsite visits and a review of risk assessments and due diligence for 244 regulated intermediaries. Risk mitigation programmes were imposed on a few firms where controls were weaker and required strengthening, and the report notes that the findings to some extent support concerns previously raised by Moneyval in its 2024 mutual evaluation of the Bailiwick. The Commission will take account of how firms incorporate the report’s findings as part of ongoing supervision and plans further outreach with the investment sector on this topic in 2026.
Guernsey Financial Services Commission 2025-12-15
Guernsey Financial Services Commission publishes thematic review on investment firms’ intermediary and correspondent relationship controls
The Guernsey Financial Services Commission released a thematic review on investment firms' compliance with intermediary and correspondent relationship requirements. Most firms understood associated risks, but six areas need improvement, leading to risk mitigation programmes for firms with weaker controls. The Commission will integrate these findings into ongoing supervision and plans further outreach with the investment sector in 2026.