Financial Crime Supervisory Approach


The GFSC is committed to meeting International standards on Anti Money Laundering and Combating the Financing of Terrorism. We play a key role in Gibraltar’s overall approach to combating money laundering (ML) and terrorist financing (TF). Our risk based supervisory approach to ML/TF risks is being enhanced to ensure that it is focused, driven and separately accountable specific to the ML/TF threat to the jurisdiction so that we are able to demonstrate that any regulatory or supervisory engagement/intervention is proportionate to the level of ML/TF risk, and also takes into account the National Risk Assessment.

Over the 1st and 2nd March 2017, the GFSC delivered a number of presentations to representatives of all financial services industries, setting out its enhanced risk based supervisory approach to ML/TF risks and Financial Crime more generally. The launching of a Financial Crime Return (FCR) was also communicated.

The purpose of the FCR is to ensure that we have a thorough understanding of how susceptible or vulnerable our licensees are to ML and TF risks, and ensure that sufficient resources are allocated, based on the perceived risk, to mitigate those which sit outside our Risk Appetite and Tolerance.

Notes for completion of the FCR can be found within the actual form. The Return can be downloaded via the link below.

We have a dedicated team ready to help you with your queries. If you have any enquiries or require any support, please do contact us on or you may call us on 200 45902.

1. Financial Crime Return: Download
Links to the National Risk Assessment, the slides for the 1st and 2nd March presentations, and the legislation are available below.
2. National Risk Assessment: Download
3. Proceeds of Crime Act: Download
4. Slides: Download

Frequently Asked Questions

A: The error is due to the security levels set in your computer or network. Please see the two options below on how to address this:

1: Unblocking the file

Save the Financial Crime Return to your 'Desktop', or a relevant folder.

Right-click on the icon and select to view its 'Properties' as shown below:

Click ‘Unblock’ and then select 'OK' to confirm your choice:

2: Change the Name of the File

Save the Financial Crime Return to your Desktop or relevant folder. Open the file and Enable Editing (if applicable).

Click OK to the error shown below:

Click Save As and rename the file – it is sufficient to change just one character (e.g. adding the number 2 as shown below):

A:Your Macro Security settings are preventing the Financial Crime Return code from running. Please see one option below on how to address this:

Using Trusted Locations

In Excel, click on File and select OPTIONS.



Browse to or type in the path to your folder.

Finally, save the FSC Financial Crime Return in that same folder so that Excel will not object to running it.

A:No, at present no information is being sought from private funds.

A:Yes, a private fund will be a customer of the Fund Administrator and therefore should be accounted for in its Return.

A:The fund will be the customer of the Fund Administrator. Information relating to the underlying investors will be reported by the Fund separately

A:Information required with respect to the residency and nationality of a customer, should be provided for all beneficial owners of the company. Information required with respect to the activity, should be taken to be the activity of the company.