In its 2024 MONEYVAL evaluation, the Bailiwick of Guernsey was rated Compliant with Recommendation 16, which governs the traceability and transparency of wire transfers. This recommendation requires that accurate originator and beneficiary information accompanies all qualifying wire transfers and that financial institutions maintain procedures to detect and respond to transactions lacking this information. Guernsey’s legal and regulatory system was found to be in full alignment with these standards, reflecting years of sustained development and risk-based policymaking.

Regulatory Framework & Supervision

Guernsey has implemented a dedicated legislative regime for wire transfers under the Transfer of Funds Ordinance 2017, which is fully aligned with the FATF’s Recommendation 16. Financial institutions are required to include and retain complete originator and beneficiary information on all qualifying wire transfers. These obligations apply to both domestic and cross-border transfers, and competent authorities have access to this information in a timely manner.

The supervisory authority, the Guernsey Financial Services Commission (GFSC), conducts rigorous, risk-based oversight of compliance with wire transfer rules across sectors. Enforcement mechanisms are in place for dealing with breaches, and guidance has been issued to assist firms in understanding and applying their obligations effectively. The evaluation confirmed that procedures to monitor and reject non-compliant transfers are active and functioning as intended.

The GFSC ensures that both ordering and intermediary institutions maintain the necessary standards, while beneficiary institutions are subject to identity verification and recordkeeping requirements. Record retention, due diligence, and sanctions compliance obligations are well understood and embedded across all relevant financial service providers.

Effectiveness & Sector Engagement

Guernsey’s financial institutions, particularly its banks and trust and corporate service providers (TCSPs), demonstrated a strong grasp of their responsibilities under the wire transfer framework. The compliance culture was observed to be mature and risk-sensitive, bolstered by ongoing outreach, training, and thematic reviews led by the GFSC and the Financial Intelligence Unit (FIU).

Despite Guernsey’s relatively small scale and low domestic crime rates, the jurisdiction is highly exposed to international financial flows and foreign predicate offences. Consequently, Recommendation 16 compliance plays a critical role in its broader anti-money laundering (AML) and counter-terrorist financing (CFT) strategy. Guernsey’s implementation of this recommendation reflects a proactive approach to mitigating the risk of illicit financial flows through its internationally connected financial system.

Conclusion

Guernsey’s fully compliant rating for Recommendation 16 affirms the strength of its legal and supervisory framework for managing wire transfers. The jurisdiction’s laws ensure the traceability of funds, while supervisory bodies provide rigorous oversight, and financial institutions maintain a strong culture of compliance. These elements collectively reinforce the integrity of Guernsey’s financial system and contribute to its reputation as a robust international financial centre committed to high AML/CFT standards.