Under Guernsey Financial Services Commission's (GFSC)
revised Handbook on Countering Financial Crime and Terrorist
Financing (the Handbook), which took effect on 31 March 2019, firms
were required to take account of the conclusions of Guernsey's
(yet to be published) National Risk Assessment (NRA) in undertaking
their business risk assessments (BRAs) and reviewing their AML/CFT
policies, procedures and controls.
Transitional provisions included in the revised regime allowed
firms four months from the date of the NRA's publication
– which was previously expected in October – to review
their BRAs, and three months thereafter to approve revisions to
their policies, procedures and controls.