AML/CFT guidance for registered directors

The Commission has today issued in final draft form guidance for registered directors on their anti-money laundering and counter terrorist financing ("AML/CFT") obligations.

This follows the introduction last month of a director registration regime for individuals using the up to six directorships exemption from fiduciary licensing where no other exemption from registration applies.

This guidance is being issued in draft form to allow for addressing any technical issues with the guidance which could hinder or prevent a registered director complying with their AML/CFT obligations. It will be issued in final form when the AML/CFT obligations upon registered directors, contained in Schedule 3 of the Criminal Justice (Proceeds of Crime) ( Bailiwick of Guernsey) Law, 1999, take effect from 1 October 2023.

This guidance is for registered directors only as it reflects the very limited activity they can undertake. It takes account of feedback from the consultations held late last year on the establishment of a director registration regime.