DRR Return Guidance (Form 155 & Form 236)

Summary

This is guidance from the Guernsey Financial Services Commission's Financial Crime Division explaining how to complete two forms used under the Director Registration Regime (DRR): Form 155 (the DRR Return) and Form 236 (the De-registration Notification). It applies to individuals who register with the Commission because they rely on the 'six directorship exemption' in section 3(1)(g) of the Fiduciaries Law, and walks through each page and question of the online DRR Return.

• Who must register/report: Individuals acting as directors under the section 3(1)(g) six directorship exemption who are not otherwise exempted under paragraphs 1(2) and 1(3) of Schedule 5 to the Proceeds of Crime Law.
• DRR Return content: Registrants must disclose personal solvency proceedings and disqualifications where applicable, and provide details of each in scope directorship, including the company's activities, jurisdictions of operation, and (where relevant) jurisdiction of trustee, economic settlor and beneficial owners.
• Annual validation: After initial two part registration, the DRR Return must be submitted annually by 14 November to validate previously provided information; interim updates to directorship information are not otherwise required.
• De-registration: Individuals who no longer hold in scope directorships, whose remaining directorships are all exempt under Schedule 5 paragraphs 1(2) and 1(3), or who become licensed Personal Fiduciary Licensees, must submit Form 236 instead of the DRR Return.
• Corrections: Errors in a submission or changes to personal details (name, address, email) must be reported via the Online Portal's secure messaging facility rather than by amending the submitted form.

The guidance is procedural and interpretive rather than a standalone legal instrument; the underlying obligations to register, pay fees and provide information derive from Schedule 5 to the Proceeds of Crime Law and the Fiduciaries Law, which this document explains how to satisfy in practice.

Key obligations

• Registrants completing the DRR Return for the second or subsequent time must submit it annually by 14 November to validate their directorship information.
• Registrants must fully complete all mandatory sections of the DRR Return, including solvency and disqualification disclosures where applicable.
• Registrants must make a full and frank disclosure of any personal solvency proceedings if they answer yes to the solvency questions.
• Registrants must provide details of any disqualifications if they answer yes to the disqualifications question.
• Individuals no longer required to be registered under the Director Registration Regime must submit a De-registration Notification (Form 236) instead of the DRR Return.
• Registrants must confirm, before submission, that the information supplied is complete and correct to the best of their knowledge and that they have read the guidance document.
• Errors in an original submission or changes to personal information (name, address, email) must be notified to the Commission via the Online Portal's secure messaging facility, not by resubmission.

Applies to

individuals registered under the Director Registration Regime, directors utilising the section 3(1)(g) six directorship exemption under the Fiduciaries Law, Personal Fiduciary Licensees

Deadlines

• annually by 14 November: DRR Return (Form 155) must be submitted annually by this date to validate directorship information for registrants completing it for the second or subsequent time.