National Risk Assessment
National Risk Assessment / National Strategy
The Financial Intelligence Unit in conjunction with the other Bailiwick of Guernsey competent authorities, takes a risk-based approach towards money laundering, terrorist and proliferation financing risks when analysing and developing information obtained from suspicious activity reports and other relevant information. The FIU and other authorities, identity, assess and understand the money laundering, terrorist financing and proliferation financing (ML/TF/PF) risks to which they are exposed and focus their resources on the areas of risk and vulnerabilities identified in the Bailiwicks National Risk Assessment (NRA) which was originally published in January 2020 in accordance with the requirement in the Financial Action Task Force Recommendations.
The NRA was updated in December 2023 with the greatest risk to money laundering being identified as foreign criminality flowing through banks and trust and company service providers, which is consistent with the findings of the previous NRA. The risk from domestic criminality comes from drug trafficking and fraud which is considered lower risk, and the risk from terrorist financing is from cross border business which is used to support foreign terrorism, with funds passing through or administered from Guernsey, but this is considered much lower risk than money laundering. The risks from proliferation of weapons of mass destruction are considered to be the same a terrorist financing i.e. low risk.
The revised NRA(2) allows the FIU to identify, assess and understand the external and domestic risks it faces and assists the other AML/CFT/CPF authorities to mitigate those risks. This includes the risk that Guernsey's financial services businesses may be used to launder the proceeds of crime (for example proceeds generated by bribery, corruption, fraud and tax evasion etc.) and to facilitate terrorist and proliferation financing.
As part of the Bailiwick of Guernsey's long-term commitment to preventing and eliminating money laundering, terrorist financing and the financing of proliferation of weapons of mass destruction (financial crime), and to support the revised NRA(2) the Bailiwick has published a National Strategy for combatting money laundering, financing of terrorism and financing of proliferation. The strategy includes a vision, a risk assessment and risk appetite and a description of the Bailiwicks strategic priorities for the implementation of the FATF standards.
In addition to NRA1 and NRA2, the States of Guernsey has published a report concerning the Bailiwick of Guernsey's money laundering, terrorist financing and financing of proliferation of weapons of mass destruction risks from legal persons and legal arrangements. The report follows, and supplements, the Bailiwick of Guernsey's second National Risk Assessment, also known as NRA2, which was published in December 2023.
When NRA2 was published at the end of 2023, it was decided to publish a separate risk assessment of legal persons and legal arrangements in 2024, in order to facilitate maximum benefit to all stakeholders and ease of use.
The States of Guernsey has created a useful website that provides an overview of key information including Financial Sanctions, FATF/MoneyVal updates and details of the Bailiwick's National strategies. Further information can be found on Financial Crime by clicking here. Additional details can be found on the National Risk Assessment by clicking here, and information on the Bailiwicks National Strategy can be found by clicking here.