Due to the ongoing delays to the publication of Guernsey’s National Risk Assessment, the following advice has recently been released by the GFSC. Although a consultation in the first instance, it is likely that the changes will be passed and incorporated into an update to Chapter 17 of the AML Handbook. In essence the changes now define a firm date of February 2020 for Board approved BRA reviews to have been undertaken, and an additional 3 months (end May 2020) for policies, procedures and controls to be updated accordingly. Consideration of the NRA, and providing evidence thereof, should now take place during the next BRA review phase.
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