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SEMINAR: Suspicious Activity Reporting and Changes to the Legal Framework

During May 2014, the Financial Investigation Unit (FIU) and the Guernsey Financial Services Commission (GFSC) held a co-sponsored seminar entitled "Suspicious Activity Reporting" which covered trends, tips, analysis and engagement.

The aim of the seminar was to provide industry with the latest information in relation to suspicious activity reporting. The seminar focused on four main areas:- 

    - The law surrounding suspicious activity reporting and proposed new changes to legislation;
- Best practice in relation to the preparation of Suspicious Activity Reports (SARs) and the use of THEMIS;
- The GFSC's expectations relating to firms' compliance arrangements regarding suspicious activity reporting;
- On-site AML/CFT visits and the GFSC's role in tackling vulnerable areas identified by suspicious activity reporting.

The slides presented by the FIU in relation to "Best Practices for SARs and New Changes to Legislation" and "Reporting to the FIS Using THEMIS" are available below (for reference purposes only).  A summary of the presentation made  by  the  representative  from  the  GFSC  can  be  accessed  on their website.

CONSULTATION PAPER - Proposed changes to the Bailiwick's criminal justice framework

The presentation also provided the financial industry with an update on the proposed changes to the Bailiwick's criminal justice framework in respect of money laundering and terrorist financing, specifically the disclosure of suspicion and obtaining additional information.

Her Majesty's Procureur has advised that any changes to the regulations should only be done after consultation with all affected parties.  The Home Department Minister has therefore  issued a consultation paper in relation to the proposed changes which is available below.