Guernsey AML 2026: GFSC Handbook Changes, Enforcement and What Firms Should Do
Guernsey's regulator consulted on Handbook changes after the 2025 MONEYVAL report, updated its higher-risk list and fined a fiduciary £450,000. Here is what firms and professionals should note.
Guernsey is one of the Channel Islands' main centres for funds, trusts and fiduciary business, and its financial crime rules matter to firms and advisers who work with Bailiwick structures. The Guernsey Financial Services Commission (GFSC) has been active in 2026, consulting on changes to its Handbook, updating its list of higher-risk jurisdictions and fining a fiduciary for systemic failures. This guide summarises those developments, based on law firm Mourant's Guernsey FinReg Quarterly Update for July to September 2026. It is general information, so check the GFSC's own notices before you act.
Why the Handbook is being reviewed
Mourant reports that the GFSC and the Policy and Resources Committee issued a joint consultation on amending the Handbook on Countering Financial Crime (AML, counter-terrorist financing and counter-proliferation financing), together with Schedules 1, 3 and 4 of the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999. The changes respond to recommended actions in the evaluation report published by MONEYVAL, the Council of Europe's AML evaluation body, in February 2025. The consultation closed on 9 October 2026, so the next step is the regulator's feedback and any final amendments. Watch the GFSC's website for the outcome.
Appendix C and reliable introducers
The consultation also sought views on Handbook Appendix C, the list of jurisdictions with standards equivalent to those of the Financial Action Task Force (FATF). The list is used for the reliable introducer and intermediary provisions, and, according to Mourant, opinions on keeping it differ. If you rely on introduced business, follow the outcome closely, because the list affects what you can accept from third parties. Our guide to reliance on third parties for customer due diligence explains the general risks of relying on someone else's checks.
Higher-risk jurisdictions: Appendix I
Mourant reports the following changes to Handbook Appendix I.
- Entries for Iraq and Bosnia and Herzegovina were amended.
- Namibia was removed from the higher-risk list.
- Algeria remains on Appendix I even though the FATF removed it from its increased monitoring list, because other external sources still list it.
The last point is a useful reminder. A FATF delisting does not automatically mean a local regulator will stop treating a country as higher risk. Our explainer on the FATF and its grey and black lists covers how those lists work.
Financial crime returns
The Financial Crime Returns Rules were amended to reflect the renaming of Form 152 from Financial Crime Risk, Intermediary Annual Return, to Financial Crime Risk, Investment Vehicles Return. The change covers the form's name, content, reporting period and submission deadline. According to Mourant, no other financial crime return is affected. If you complete this form, check the revised content and deadline.
Enforcement: a £450,000 fine
The GFSC fined licensed fiduciary Artemis Trustees Limited £450,000 for serious and systemic failures in monitoring and managing customer financial crime risk. Mourant states that these breached the 2007 Financial Services Businesses Regulations and the Handbook. The GFSC also found failings under the Corporate Governance Code for Trust Service Providers and the Principles of Conduct of Finance Business. Individuals connected to the licensee received public statements and financial penalties, with amounts not stated, and one individual is prohibited for five years and six months from acting as a controller, director, partner, manager, money laundering reporting officer (MLRO) or money laundering compliance officer.
The case is a reminder that fiduciary firms are judged on how they monitor and manage customer risk over time, not only at onboarding. Our guide to the obligations of trust and company service providers covers the general expectations, and the personal consequences for individuals show why the MLRO role carries real weight.
Other items to note
The same update mentions a proposed Crown Dependencies framework on authorised push payment fraud, being developed with the Isle of Man and Jersey regulators. It is still only a proposal and targets retail banking customers and sterling payments made through Faster Payments and CHAPS. Mourant also reports tokenisation guidance and the removal of a blanket restriction on virtual asset service provider licensees serving retail customers, with stablecoin rules planned for autumn 2026. The update contains no items on beneficial ownership.
What firms should do now
- Review your customer risk assessment against the latest Appendix I.
- Check whether you use Appendix C for reliable introducers and prepare for any change.
- If you file Form 152, confirm the new name, content and deadline.
- Test how you monitor customers over time, and keep evidence of the results.
- Make sure the board and the MLRO understand personal accountability.
- Follow the GFSC's response to the consultation.
Frequently asked questions
What prompted the Handbook consultation?
Recommended actions in MONEYVAL's evaluation report, published in February 2025.
When did the consultation close?
9 October 2026.
Was Namibia removed from the higher-risk list?
Yes, according to Mourant's summary of the Appendix I update.
How much was the fiduciary fined?
£450,000, according to Mourant's report of the GFSC decision.
Next steps
Update your risk assessments and procedures for the Appendix I changes, then watch for the GFSC's consultation feedback. For further training, explore Learnsignal's CPD courses.
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