Guernsey updates compliance audit requirement
The Guernsey Financial Services Commission (GFSC) has updated its compliance audit requirement, applicable to any GFSC licensed businesses.
This means GPs are in scope and must establish ‘where appropriate’ an independent audit function to monitor their AML/CFT policies and procedures.
Further, a compliance monitoring programme (CMP) must be implemented to assess the application of related policies.
It is up to the fund manager to decide whether this role should be filled internally or externally.
However, internal employees cannot fulfil this function if they were involved in the creation of the procedures or of the CMP.
Chris Hutley-Hurst, partner at Walkers, commented on the implication of this update for fund managers: "Guernsey GPs and Guernsey managers that are regulated in Guernsey will need to consider whether, based on the nature and size of their business and its associated risks, it is appropriate for them to establish an independent compliance audit function. Where they do establish the function, they will need to consider the regularity of the audit, and decide whether it is carried out by internal persons (who are sufficiently independent of the creation and maintenance of the processes and procedures being audited), at group level, or by an external service provider."
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