Instructions and Notices - Business From Sensitive Sources - Record of Changes (December 2007 – June 2020)

Summary

This is an archived, superseded historical log maintained by the GFSC recording the succession of Business From Sensitive Sources Notices and Instructions issued between December 2007 and June 2020 to Financial Services Businesses (FSBs) and Prescribed Businesses (PBs). Each entry summarises a specific dated Notice or Instruction, the countries or territories it identified as sensitive or high risk, and confirms which prior Notice or Instruction it repealed and replaced. The document itself does not create standalone obligations beyond restating what each historic Notice/Instruction required at the time.

• Nature of record: A chronological table tracking each successive Business From Sensitive Sources Notice or Instruction, its issue date, recipients (FSBs or PBs), and the jurisdictions of concern it listed.
• Recurring requirement pattern: Each active Notice/Instruction in its time required FSBs and PBs to exercise greater caution and apply enhanced customer due diligence to business relationships and transactions connected with the listed sensitive jurisdictions, and in some cases (e.g. Iran-related entries) to review existing relationships and check for use of correspondent relationships to evade counter-measures.
• Specific exposure checks: Certain Instructions (e.g. Number 6/8 of November 2009) required immediate consideration of exposure to named sanctioned persons (Bank Mellat, IRISL) and reporting any exposure to the Commission's intelligence team.
• Superseded status: Every listed Notice or Instruction was itself repealed and replaced by a later one; the final entry (19 June 2020) records that SB Instruction Number 01/2020 was repealed, with current guidance now found in Appendices H and I to the Handbook on Countering Financial Crime and Terrorist Financing.

Because the entire chain of Notices and Instructions summarised here has been repealed and superseded, this archive document has no continuing legal effect on its own; it is retained for historical reference only. Current obligations regarding sensitive/high-risk jurisdictions are set out in the GFSC Handbook on Countering Financial Crime and Terrorist Financing, not in this record.

Applies to

Financial Services Businesses (FSBs), Prescribed Businesses (PBs)