Thematic Review of ML and TF Business Risk Assessments

15th December 2022

The Commission has today issued its report on the thematic review of the money laundering and terrorist financing business risk assessments of more than 100 licensed and registered firms across all sectors. The thematic was undertaken to assess how well firms identified and assessed these risks to their businesses. The results were positive, demonstrating that most Business Risk Assessments met the Bailiwick’s regulatory requirements. A copy of the thematic review is available via the following link: 

Money Laundering and Terrorist Financing Business Risk Assessments - Thematic Review 2022

These assessments are important elements for the setting of appropriate risk-commensurate controls within firms.  

We noted many examples of good practice during our review. Nevertheless, seven areas for improvement were identified where firms could improve their risk assessments, of which there were two key areas.  Firstly, firms could benefit from additional research and using the National Risk Assessment to help them improve upon identifying the terrorist financing risks relevant to their businesses through their customers; jurisdictions; products; services; transactions and delivery channels.  Secondly, firms are advised to make more use of their management information to ensure that the assessments are relevant and tailored to the business.

We will be holding an industry event in 2023 to discuss the findings. Invitations will be sent out in due course. In the meantime, all firms are encouraged to consider the report’s contents, particularly when updating and revising their business risk assessments.