Thematic Review of Governance, Risk and Compliance Controls to Counter Financial Crime – Estate Agency, Legal and Accountancy Services

The Commission has today issued its report on the Thematic Review of Governance, Risk and Compliance Controls to Counter Financial Crime – Estate Agency, Legal and Accountancy Services.  Towards the end of 2023 the Commission’s Financial Crime Division undertook a thematic review of the financial crime controls implemented within businesses registered with the Commission as prescribed businesses for the purposes of financial crime supervision.

As part of its thematic review, the Commission visited 18 of the 107 registered firms representing a range of business activities and services provided by the sector, meeting with representatives of each firm and reviewing a number of customer files per firm for compliance with the Bailiwick’s financial crime regime.

A copy of the thematic review is available via the legislation and guidance page or via this link.

All firms supervised by the Commission, and not just prescribed businesses, will find areas within the report which will be relevant to their own businesses.  The report also contains a self-assurance question set designed to assist firms in strengthening their existing policies, procedures, and controls.

The Commission will be hosting workshops on the thematic for each of the three prescribed business sub-sectors over the coming months, to which all relevant firms registered with the Commission will be invited. In the meantime, all firms are encouraged to consider the report’s contents, particularly in relation to the areas for improvement and self-assurance questionnaire when updating and revising their policies, procedures, and controls.