Financial Crime Risk Return (Form 151) Template

Summary

This is the template for Form 151, the Financial Crime Risk Return (FCRR), used by the Guernsey Financial Services Commission to collect statistical and risk data on financial crime from regulated firms. It covers a reporting period running from 1 July of one year to 30 June of the next, and the data feeds the Commission's supervisory view of financial crime risk at firm, sector and industry level.

• Who must file: All licensed and registered firms and individuals, including administered and managed entities, whose business activities are subject to the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999 and the Handbook on Countering Financial Crime and Terrorist Financing.
• Reporting Suspicion: Details of internal and external disclosures to the MLRO/Nominated Officer and the FIS, broken down by predicate crime category, PEP status, 'no consent' cases, FIS information requests and tax disclosure facility usage.
• Governance and Controls: Information on group structure, significant business changes, staffing, board review of ML/TF risk assessments, compliance monitoring, independent audit/testing of AML/CFT controls, transaction monitoring timing, PEP/adverse media/sanctions screening frequency and systems, ML/FT risk review frequency, and outsourcing of AML/CFT functions.
• Relationships: Volumes of business relationships and occasional transactions, high risk relationships, PEP relationships (foreign, domestic, international organisation), PEP declassification, sanctioned-party referrals, intermediary and introducer reliance, pooled accounts, and relationships exited or declined for risk reasons.
• Geographical: Geographic breakdown of business relationships and occasional transactions by jurisdiction of the customer or beneficial owner, submitted via an accompanying spreadsheet.
• Declaration: A signed confirmation that the information is complete and correct, that the guidance document has been read, and an undertaking to inform the Commission without delay of any material changes to the information supplied.

The document is purely a form template illustrating all possible questions (some conditional) that appear in the live online FCRR; it does not itself set out separate legal obligations beyond directing firms to complete and submit the Return using the Commission's guidance document.

Key obligations

• Licensed and registered firms and individuals (including administered and managed entities) must submit one FCRR covering all business activities subject to the Proceeds of Crime Law and the Handbook on Countering Financial Crime and Terrorist Financing for each reporting period (1 July to 30 June).
• Firms must complete all sections of the FCRR fully, entering '0' where a question does not apply or the firm has no business in that area.
• Firms must not include information identifying underlying parties subject to disclosures made.
• Before submission, the firm must confirm it has read the guidance document and that the information supplied is complete and correct.
• Firms must inform the Commission without delay of any material changes to the information supplied on the form after submission.

Applies to

licensed and registered firms and individuals, administered and managed entities

Deadlines

• 1 July to 30 June annually: Reporting Period covered by each Financial Crime Risk Return, with data given as at the end of the period or accumulated occurrences within it