Thematic Review: Correspondent and intermediary relationships in the investment sector

The Commission has today issued its report on the thematic review on the effectiveness of investment firms’ monitoring of, and compliance with, the intermediary and correspondent relationship requirements of the Handbook on Countering Financial Crime (AML/CFT/CPF) (the “Handbook”) which we invite all firms who have these relationships to consider.

We undertook 30 onsite visits as part of this review and reviewed the risk assessments and due diligence for 244 regulated intermediaries.  The review identified that most firms had a good risk understanding of these types of relationships and appropriate controls. Nonetheless, risk mitigation programmes were imposed on a few firms whose controls were weaker and required strengthening. Moreover, we identified six areas for improvement which all firms that have these relationships should take note of.

This topic was an area where Moneyval identified some weakness in the controls used by the investment sector to identify, understand and manage the risks posed by these types of relationships, in its mutual evaluation of the Bailiwick in 2024. The findings from our review to some extent, support Moneyval’s concerns.

A copy of the thematic review is available here or via the Commission's Legislation and Guidance page under the 'Thematic Reviews' heading.

We wish to thank those firms that participated in the thematic review through the completion of the thematic questionnaire, together with those that also participated in the onsite visits. The Commission will consider how firms have incorporated the findings from this report as part of its ongoing supervision.  Further outreach with the investment sector on this topic will be conducted in 2026.