Handbook on Countering Financial Crime (AML/CFT/CPF) (7 July 2026)

Summary

This is the Guernsey Financial Services Commission's consolidated Handbook on Countering Financial Crime (AML/CFT/CPF), dated 7 July 2026. It sets out the Commission's Rules and guidance that specified businesses in the Bailiwick of Guernsey must follow to comply with Schedule 3 to the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999 and related AML, CFT and sanctions legislation.

It applies to all 'specified businesses' conducting financial services business (FSB) or prescribed business (PB) in the Bailiwick, including Bailiwick branches of overseas firms, natural persons, legal persons and legal arrangements such as companies, partnerships and sole traders. Schedule 3 itself remains the legally enforceable text; the Handbook is the Commission's interpretation and expected standards, non-compliance with which courts may take into account when assessing breaches of Schedule 3.

• Governance and risk: Corporate governance requirements and a risk-based approach to assessing and mitigating ML, TF and PF risk (Chapters 2 to 3).
• Customer due diligence: CDD, enhanced CDD, simplified CDD, natural person identification, electronic ID&V, and specific rules for legal persons, legal arrangements and introduced business (Chapters 4 to 10).
• Ongoing monitoring and sanctions: Monitoring of transactions and activity, and compliance with UN, UK and other targeted financial sanctions regimes (Chapters 11 to 12).
• Reporting suspicion: Obligations to report suspected ML, TF and PF activity, including via THEMIS, and rules on tipping off (Chapter 13).
• Wire transfers: Obligations on payment service providers as payer, payee and intermediary in wire transfers, including batch file and record keeping requirements (Chapter 14).
• Employees and records: Employee screening and training requirements, and record keeping obligations (Chapters 15 to 16).
• Transitional provisions: Specific transitional rules covering business risk assessments, existing business relationships, MLCO/MLRO arrangements and nominated firms for investor CDD (Chapter 17).
• Virtual assets: Dedicated CDD, enhanced CDD, correspondent relationship and transfer requirements for virtual asset activity (Chapter 18).

The Handbook also includes appendices covering the glossary, equivalent jurisdictions, sector-specific guidance, domestic PEP lists, an introducer certificate template, the full text of Schedule 3, and lists of high-risk and higher-risk jurisdictions, which firms must consult when applying risk-based due diligence.

Key obligations

• Firms must apply a risk-based approach to assess and mitigate money laundering, terrorist financing and proliferation financing risk in line with Schedule 3 and the Commission Rules.
• Firms must conduct customer due diligence, including enhanced or simplified measures where appropriate, on natural persons, legal persons and legal arrangements.
• Firms must monitor customer activity and ongoing business relationships for suspicious or unusual activity.
• Firms must report suspected money laundering, terrorist financing or proliferation financing activity, and must not tip off customers about such reports.
• Firms must screen and train employees on AML/CFT/CPF requirements.
• Firms must keep records of CDD, transactions and training as required by Schedule 3 and the Handbook.
• Firms must comply with UN, UK and other applicable targeted financial sanctions, including customer screening and reporting to the Commission.
• Payment service providers must comply with wire transfer information and record keeping requirements when acting as payer, payee or intermediary.
• Firms engaged in virtual asset activity must apply specified CDD, enhanced CDD and transfer-related requirements set out in Chapter 18.
• Licensed firms should maintain policies, procedures and controls in line with Schedule 3 and the Handbook to support a defence of having 'prevention procedures' against failure-to-prevent ML/TF offences under section 48MA of the Law and section 74A of the Terrorism Law.

Applies to

financial services businesses (FSB), prescribed businesses (PB), Bailiwick branches of overseas companies conducting FSB or PB, trust and corporate service providers (TCSPs), virtual asset service providers (VASPs), payment service providers (PSPs), money service providers (MSPs), natural persons, legal persons and legal arrangements conducting specified business, including companies, partnerships and sole traders

Related documents

• This document is made under Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999
• This document is made under Terrorism and Crime (Bailiwick of Guernsey) Law, 2002 (Consolidated text)
• This document is made under Transfer of Funds (Alderney) Ordinance, 2017
• This document is made under Transfer of Funds (Guernsey) Ordinance, 2017
• This document is made under Transfer of Funds (Sark) Ordinance, 2017