New Documents

HM Treasury’s Office of Financial Sanctions Implementation published a notice providing details on amendments to the sanctions entries for three individuals and one entity designated under the Russia (Sanctions) (EU Exit) Regulations 2019.

HM Treasury’s Office of Financial Sanctions Implementation issued a notice concerning the addition of 42 individuals and 44 entities to the consolidated list pursuant to the Russia (Sanctions) (EU Exit) Regulations 2019.


Enforcement Actions

The Guernsey Financial Services Commission penalized the St. Peter Port, Guernsey-based asset management company in the amount of £203,000 and fined the managing director of the company, Hamish Jebb Hamilton Few, £33,810 for regulatory noncompliance.

The Guernsey Financial Services Commission imposed a penalty of £87,500 on Geoffrey John Trebert and banned him from holding the position of controller, director, partner, manager, money laundering reporting officer, and money laundering compliance officer for a period of two years and ten months.

Important Facts

  • The U.S. State Department labels the Bailiwick of Guernsey as a jurisdiction of primary concern. The Bailiwick of Guernsey encompasses a number of the Channel Islands – Guernsey, Alderney, Sark and Herm. As a Crown Dependency of the United Kingdom, Guernsey relies on the United Kingdom for its defense and international relations. Although Alderney and Sark have separate parliaments and civil law systems, Guernsey’s parliament legislates in matters of criminal justice for all islands in the Bailiwick. Due to its status as a financial center, there is a risk that criminal proceeds will be invested in or pass through the Bailiwick. Since the majority of customers of Bailiwick businesses are based elsewhere, any illicit proceeds are likely to arise from foreign predicate offenses. However, the highest overall number of money laundering cases arise from domestic criminal activity, such as drug trafficking.
  • KYC Covered Entities: Banks, lending firms, financial instrument issuers and managers, and money service businesses; insurance companies and intermediaries; investment firms and funds; safekeeping and portfolio management services; trust and company service providers; lawyers, accountants, notaries, and estate agents; dealers of precious metals and stones; and e-gaming services
  • STR Covered Entities: All businesses
  • Enhanced Due Diligence Procedures for PEPs: Foreign: Yes; Domestic: No
  • Money Laundering Criminal Prosecutions/Convictions: Prosecutions: 3 (2015); Convictions: 3 (2015)
-Source: 2016 International Narcotics Control Strategy Report (INCSR)



Technical Effectiveness
Compliant : 25 High :
Largely Compliant : 22 Substantial :
Partially Compliant : 2 Moderate :
Non-Compliant : 0 Low :


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Tax Justice Network i

Rank : 11/133
Score : 71/100