Financial Crime Risk Return (Form 151) Guidance

Summary

This is guidance from the GFSC's Financial Crime Division explaining how firms should complete the Financial Crime Risk Return (Form 151, the FCRR), an annual data-collection return used by the Commission to assess money laundering and terrorist financing risk across firms, sectors and the industry as a whole. It works through the return section by section (Reporting Suspicion, Governance and Controls, Relationships, Geographical, Declaration) and defines key terms used in the form.

• Who must file: All licensed and registered Firms (financial services businesses and prescribed businesses) subject to Schedule 3 and the Handbook, including administered or managed licensees, must submit one FCRR covering their relevant business activities.
• Sector-specific rules: Managed life insurance licensees complete their own FCRR; PCCs with life and non-life business file one consolidated return; investment licensees (including administered ones) and designated managers/administrators file separate returns per administered licensee; firms nominated for investor CDD must include investor statistics.
• Exemptions: Joint fiduciary licensees, personal fiduciary licensees, authorised/registered collective investment schemes, non-life insurance licence holders, and insurance intermediaries dealing solely in non-long-term business are not required to complete the FCRR.
• Reporting period: Data must be reported for the period 1 July to 30 June (the Reporting Period), with some fields (e.g. occasional transactions) requiring cumulative figures across that period.
• Content areas covered: The return and guidance address suspicious activity disclosures, governance and controls (policies, PEP/adverse media/sanctions screening, ML/FT risk review frequency, outsourcing), business relationships and PEP/intermediary data, and geographic breakdowns of customers and beneficial owners.

The guidance itself does not create new substantive AML/CFT obligations beyond directing firms on how to accurately populate and submit the annually required FCRR; the underlying obligation to submit the return by the stated deadline derives from the Commission's data collection requirement referenced in this guidance.

Key obligations

• Firms subject to the FCRR requirement must submit a completed Financial Crime Risk Return covering the Reporting Period (1 July to 30 June) by 31 October annually.
• Administered/managed licensees, PCCs, and investment licensees must follow the specific consolidation or separate-filing rules set out (e.g. one FCRR per administered licensee, consolidated PCC returns for life business).
• Where administration of a Firm transfers during the Reporting Period, the new administrator must complete and submit the FCRR using available data, while the previous administrator must report any occurrences (e.g. disclosures) arising while it was administrator.
• Firms nominated to be responsible for investor CDD under Paragraph 4.57 of the Handbook must include statistics on investors within collective investment schemes for which they are nominated.
• Firms should not proceed with FCRR completion if Firm Name or Reporting Period fields on the Start Page are incorrect, and must instead contact the Commission's Online Services Helpdesk.

Applies to

financial services businesses, prescribed businesses, banking licensees, fiduciary licensees (excluding joint and personal fiduciary licensees), investment licensees, insurance licensees (excluding non-life licence holders), non-regulated financial services businesses, administered or managed licensees

Deadlines

• 31 October annually: Deadline for submission of the completed Financial Crime Risk Return (FCRR).
• 1 July to 30 June: The Reporting Period covered by each FCRR, for which data and cumulative figures (e.g. occasional transactions) must be provided.