Instructions and Notices Issued by the GFSC - Business From Sensitive Sources: Record of Changes (2017-12-05)

Summary

This document is a chronological register maintained by the Guernsey Financial Services Commission (GFSC) tracking every Notice and Instruction issued under its 'Business from Sensitive Sources' regime from December 2007 through 5 December 2017. Each entry records when a new Notice/Instruction was issued, which prior one it repealed, and which countries or territories were added to or removed from the lists of high-risk, non-cooperative, or otherwise sensitive jurisdictions. It is a historical log rather than a standalone substantive rule, but the most recent entry (Instruction 04/2017) is the version currently in force.

• Who it covers: Financial Services Businesses (FSBs) and Prescribed Businesses (PBs), each of which received parallel but separately numbered Notices/Instructions over time.
• Core requirement tracked: Each successive Notice/Instruction required FSBs/PBs to exercise a greater degree of caution and apply enhanced customer due diligence to business relationships and transactions connected with the listed sensitive countries or territories.
• Specific past actions: Some entries (e.g. Instruction Number 8/2009) required firms to immediately check for exposure to named sanctioned persons (such as Bank Mellat and IRISL) and report any exposure to the Commission's intelligence team.
• Superseding pattern: Each new Notice or Instruction expressly repealed and replaced the immediately preceding one, so only the most recent instruction in the chain is operative at any given time.
• Latest entry: Instruction 04/2017 (5 December 2017) repealed Instruction 03/2017 and updated the jurisdiction lists, adding Sri Lanka, Trinidad and Tobago and Tunisia to the 'Improving Global AML/CFT Compliance' category and removing Uganda from monitoring.

Because this is a running record rather than a self-contained rule, compliance officers should identify the currently effective Instruction (the last, unrepealed entry) to determine which specific jurisdictions currently require enhanced due diligence, rather than relying on this document alone for the current list.

Key obligations

• FSBs and PBs must apply enhanced customer due diligence and special attention to business relationships and transactions connected with countries or territories identified in the currently effective Notice or Instruction.
• Where a specific instruction so requires (as with historical Instructions concerning Iran-linked entities), firms must immediately review existing business relationships and report any exposure to the Commission.
• Firms must track and apply only the most recently issued, unrepealed Notice/Instruction in this series, as each supersedes its predecessor.

Applies to

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

Deadlines

• 5 December 2017: Instruction 04/2017 took effect, repealing Instruction 03/2017 and becoming the currently applicable Business from Sensitive Sources instruction.