Applying for a permission

Bureaux de Change

 

About

The purpose of this page is to make sure the application process is fully understood.

This section sets out:

  • What a Bureau de Change is and what this regulated activity would allow you to do
  • Authorisation Process 
  • Capital Requirements
  • Additional Information

What is a Bureau de Change and what would this regulated activity allow you to do?

A Bureau de Change is an establishment at which customers, primarily, exchange foreign money. This regulated activity will allow you to offer the service of exchanging currency as a Bureau de Change. This permission, to carry out regulated activity, would be granted under Part 7 of the Financial Services Act. 

 

Application process

Following successful completion of the pre-application process, applicants should submit an application in line with the Staged Application for Authorisation Approach.

Initially, the applicant will only submit the Stage 1 application information - it is important that only Stage 1 information is provided at the outset of the application process.

The GFSC will communicate to the applicant that the application can progress to the next stage once the GFSC is satisfied with the content provided at the current stage. The applicant will then be invited to submit the further information required at the next stage of the application process.

Please request cloud access from the GFSC to submit the information requested, via e-mail to [email protected], stating in the subject field: ‘Name of Applicant – Application’.  Paper copies are not required unless indicated by the team.

Please note that we accept signed signature copies sent via e-mail and electronic signatures, which must originate from the Regulated Firm /Applicant’s domain.  

Stage 1 - Business Model, Capital & Key Individuals

The following is to be submitted for Stage 1: 

On receipt of the application fee and Stage 1 documents, the GFSC will confirm the GFSC Supervisor who has been assigned to assess the application for authorisation.

Any missing or additional sector-specific documents and/or information required by the GFSC to complete Stage 1 will be communicated to the applicant during Stage 1.

When the GFSC is satisfied with all the responses and information/documentation received, the GFSC will inform the applicant that its application can progress to Stage 2.  

Stage 2 - Risk Management, IT Systems, Corporate Governance & Financial Crime

The following is to be submitted for Stage 2: 

  • Stage 2 of the General Comprehensive Business Plan (not including Stage 3);
  • Documentation and information including, but not limited to:
    • Corporate Governance and control
    • Business Continuity Management Plan
    • IT infrastructure, Cyber and systems including outsourcing arrangements
    • Operational & Outsourcing Risk including material outsourcing arrangements
    • Systems controls & Risk Management
    • Financial Crime controls, compliance with Anti-Money Laundering/Combating the Financing of Terrorism requirements (as applicable)
    • Risk Methodology and framework policy documents
    • Risk Register & controls
    • Disaster Recovery Plan 
    • Updated business plan, if required.

Any missing or additional sector-specific documents and/or information required by the GFSC to complete Stage 2 will be communicated to the applicant during Stage 2.

When the GFSC is satisfied with all the responses and information/documentation received from an applicant, the GFSC will inform the applicant that its application can progress to Stage 3.

Stage 3 - Conduct of Business, Non-Financial Resource, Policies & Procedures

The following is to be submitted for Stage 3: 

  • Stage 3 of the General Comprehensive Business Plan;
  • Documentation and information including, but not limited to:
    • Non-financial resources
    • Compliance structure
    • Conduct of Business (Full Conduct Risk Framework documents)
    • Detail of KPIs
    • Consumer Duty compliance (as applicable)
    • Operational Resilience compliance (as applicable)
    • Remuneration Policy 
    • Conflict of Interest Policy
    • Conflict of Interest Register
    • Liquidity/solvency policies 
    • Internal Audit Plan 
    • Complaints Handling Policy 
    • Terms of Reference of the Board, Board sub-committees, Risk Committee and/or Audit Committee, Underwriting/Pricing committees, as applicable 
    • Audit, accounting, and banking arrangements 
    • Professional Indemnity Insurance 
    • Contracts with parties to whom material operational functions are outsourced 
    • Completed and signed Regulated Individual Forms and Non-Executive Director Forms
    • Mobilisation Plan (if applicable).

When the GFSC is satisfied with the Stage 3 responses and information, the application will move to a GFSC decision for authorisation.

 

Capital requirements

At present, there are no capital requirements for bureaux, however we expect firms to hold at least three months worth of expenses to ensure the orderly wind down of the firm in the event of closure.

Additional information

The regulation and supervision of bureaux is primarily aimed at countering the risks of money laundering associated with such an industry and ultimately the enhancement and protection of Gibraltar’s reputation as a leading finance centre. Therefore, applicants should ensure that they consider anti-money laundering requirements, specifically within the GFSC's AML/CFT Guidance Notes, and ensure that the firm can clearly articulate:

  1. how it complies with the requirements; and
  2. the internal controls implemented to mitigate such risk.

In determining an application, the GFSC must be satisfied that the applicant is able to execute the proposed activity diligently and has sufficient resources to adhere to all relevant obligations. Applicants must also be able to demonstrate that the business can be managed in a sound manner with adequate internal controls that can be met on a continuing basis.