Industry update on the National Strategy and National Risk Assessment

29th January 2024

Last week, more than 500 members of the financial services industry attended an update on the National Strategy and National Risk Assessment (NRA). The Bailiwick’s AML/CFT authorities once again came together to present on how the updated National Risk Assessment, or NRA2, demonstrates our understanding of the Bailiwick’s money laundering, terrorist financing and proliferation financing threats and vulnerabilities, which drives the risk-based approach taken across the AML/CFT authorities; and now covers, and importantly gives equal treatment to, countering proliferation financing.

We were encouraged by, but not surprised by, the great turnout from financial services practitioners who were keen to hear the outcomes from NRA2 and how their participation in the assessment process, through the submission of returns data to the Commission and through engagement in bespoke risk surveys, has contributed to an enhanced NRA.  

During the event, the Commission’s Director and Deputy Director of Financial Crime, Fiona Crocker and Nick Herquin, told the 500-strong audience how NRA2 represents an ‘evolution’ rather than a ‘revolution’  as like the first NRA, the key finding of the second NRA with regard to money laundering risk is that as an international finance centre with a low domestic crime rate, the Bailiwick’s greatest money risk comes from the laundering of the proceeds of foreign criminality. Whilst the risks of terrorist financing and proliferation financing for the Bailiwick are lower it still remained important for everyone to understand these risks.  The updated NRA includes the Bailiwick’s first assessment of the risks of financing of proliferation of weapons of mass destruction.

The slides used in the presentations are available on the Commission’s dedicated NRA page: National Risk Assessment (ML/TF/PF) — GFSC