Financial Crime Risk Return
3rd July 2019Financial Crime Risk Return 2019
The Financial Crime Risk Return for the reporting period 1 July 2018 to 30 June 2019 (the “2019 Return”) is available for completion on the Online Submissions Portal for all firms required to complete the 2019 Return. The submission deadline is 31 October 2019.
There are no changes to the fields within the 2019 Return, however, please note that page 13 of the guidance document has been updated to clarify how the return should be completed by investment licensees which have a business relationship with a collective investment scheme (“CIS”). Section 4.8.1. of the Handbook requires the board of an authorised or registered CIS (or General Partner of a Limited Partnership; trustee of a unit trust; or foundation official of a foundation as appropriate) to nominate a firm (the “nominated firm”) which is licensed under the Protection of Investors (Bailiwick of Guernsey) Law, 1987 as amended, and contracted to, or connected with, the CIS to be responsible for meeting the requirements of Schedule 3 and the Handbook for investors into the CIS, in addition to its own obligations. The nominated firm must treat all investors into the CIS as if they were its customers and ensure that the relevant provisions of Schedule 3 and the Handbook are met, for example, conducting relationship risk assessments and identifying, and verifying the identity of, the investors, including the beneficial owners and other key principals thereof. Accordingly, the guidance document has been updated to reflect the requirement to appoint a nominated firm.
Financial Crime Risk Return 2020
The Financial Crime Risk Return for the reporting period 1 July 2019 to 30 June 2020 (the “2020 Return”) and the guidance document will be updated following changes to the AML/CFT regime earlier this year. The 2020 Return will require information such as the number of business relationships/occasional transactions involving the different classifications of politically exposed persons, including how many have been ‘declassified’ since 31 March 2019 using the provisions set out within Section 8.5.6. of the Handbook. As such, all firms expecting to complete the 2020 Return should ensure this information is being recorded going forward.
Should you have any technical difficulties/queries relating to the Online Submissions Portal please email [email protected] or call the helpline on 01481 733420. Should you have any queries regarding how to complete the Financial Crime Risk Return, please email [email protected] .