Thematic Review on Reporting Suspicion

15th July 2021

The Commission has today issued its report on the thematic review on the reporting of suspicion of money laundering or terrorist financing. The review covered both financial services and prescribed businesses and was undertaken during the second half of 2020.

A copy of the thematic review can be found on the Financial Crime Division's Thematic Reviews page. 

All firms which took part in this industry-wide review had appointed a money laundering reporting officer (“MLRO”) and had policies and procedures for the reporting of suspicion, which provide guidance to their staff on forming a suspicion and what to do. Moreover, the vast majority of MLROs interviewed were suitably senior, qualified and independent. Nonetheless, in the majority of firms reviewed, the policies and/or procedures did not cast a full framework over the reporting process or provide comprehensive guidance for the MLRO and nominated officer on the firm’s expectations on the fulfilment of their roles.

Firms should compare their own practices and where gaps are identified, introduce updated policies, procedures and controls. It is anticipated that the areas for improvement contained within the report will lead to boards of firms applying greater oversight to the implementation and operation of the policies, procedures and controls for the timely reporting of suspicion, and ultimately improve the effectiveness of the Bailiwick at combatting money laundering and terrorist financing.

General insurers and intermediaries are not seen internationally as having a significant vulnerability to money laundering or terrorist financing and therefore are not required to comply with the AML/CFT Handbook.  However, they are required to report suspicion to the Financial Intelligence Service (“FIS”) and therefore are likely to find the findings contained within the thematic review useful.