Guernsey’s compliance with the Wire Transfer Rule is primarily governed by the Transfer of Funds (Guernsey) Ordinance 2017. This Ordinance was introduced alongside parallel laws in Sark and Alderney to implement Regulation (EU) 2015/847, which mandates information to accompany wire transfers. The Ordinance grants full legal effect to the EU Regulation within the Bailiwick, with certain local modifications. The Bailiwick, along with other Crown Dependencies, received a derogation allowing reduced information for transfers within the British Islands, recognising the equivalence of its domestic legislation with EU standards.

FATF Compliance & Legislative Objectives

The FATF Recommendations serve as the overarching framework, with the Ordinance ensuring traceability and integrity of wire transfers by requiring payment service providers to include complete payer and payee information. This assists in combatting money laundering, terrorist financing and proliferation financing. Guernsey’s approach aligns with FATF Recommendation 16, mandating that originator and beneficiary data accompany the transfer throughout the payment chain. The Regulation obliges payment service providers to implement mechanisms to detect missing information, evaluate suspicious transactions, and report them to the Financial Intelligence Unit (FIU).

Specific Obligations under the Transfer of Funds Ordinance

For outgoing wire transfers, payment service providers must ensure that accurate payer information is captured and transmitted. They must also verify whether transfers are being made on behalf of account holders or non-account holders. In cases of batch files, rules apply to both domestic and international transfers. Similarly, receiving institutions must detect incomplete data and take appropriate action. Failure to meet these requirements triggers defined compliance and reporting obligations, including suspicion reports and record-keeping duties that extend to intermediary providers as well.

Virtual Asset Transfers under WTR

The Handbook also introduces dedicated provisions for virtual asset service providers (VASPs) under Schedule 3. VASPs must collect, verify, and transmit originator and beneficiary information in line with the travel rule. This includes structured fields such as the customer’s full name, account numbers or distributed ledger addresses, national identity numbers, and other unique identifiers. Originating VASPs are prohibited from executing transfers if this information cannot be securely transmitted to the beneficiary VASP. Intermediary VASPs must also detect non-compliance and preserve data integrity throughout the transaction lifecycle.

Regulatory Oversight & Enforcement

The Guernsey Financial Services Commission monitors adherence to both the Ordinance and FATF principles. Firms must adopt a risk-based approach, taking into account both the technical requirements of the Regulation and broader compliance expectations under Schedule 3. The Commission may exercise enforcement powers for any breaches, with consequences ranging from regulatory penalties to the suspension of licences.

Conclusion: WTR Compliance Integration

Guernsey’s regulatory regime integrates the Wire Transfer Rule through comprehensive legislation and detailed supervisory guidance. The Transfer of Funds Ordinance 2017 embeds EU-aligned standards within the Bailiwick's legal structure, ensuring payer and payee data traceability and enabling the detection of illicit financial activity. With additional provisions governing virtual assets, Guernsey has established a dual-layered framework that supports FATF Recommendation 16 and positions the jurisdiction as fully engaged in global efforts to counter financial crime through effective wire transfer compliance.