A significant area of focus for the Gibraltar Financial Services Commission (GFSC) in the coming years will be ensuring that we meet all our international obligations and standards in a more uncertain environment than was anticipated a year ago.
In a post-Brexit environment, working very closely with international bodies has become more important than ever before. Against a backdrop of, amongst other things, being an exporter of financial services, the Commission needs to ensure that we are well focused and highly effective in our ability to provide credible cross border regulation and are seen to be by external stakeholders and interlocutors.
Against this backdrop, there are a number of internal changes which have taken place at the Commission to ensure continued delivery of our objectives.
The Commission has focused on delivering clear leadership within the Financial Crime area and dedicated supervisory work. We will be further developing our risk methodology to ensure that it is focused and separately accounts for money laundering and terrorist financing threats; carrying out targeted data collection from the firms we regulate so that this can form the basis of the development of our risk assessment process and increasing our engagement with firms and rolling out an enhanced Anti-Money Laundering/Combating the Financing of Terrorism (AML/CFT) supervision programme, which will be underpinned by the use of regulatory tools such as thematic reviews and assessments.
The MONEYVAL Assessment which is taking place in 2018 will be an important catalyst for the work the Commission needs to do to refine our approach to the assessment and management of AML/CFT risks.
The creation of a dedicated Financial Crime team will better align us with other regulators, as well as enabling us to better meet modern requirements on international regulators. We are pleased to announce that Annette Perales has been appointed into the position of Head of Financial Crime. Annette’s team in the first instance will be responsible for managing the MONEYVAL project and thereafter ensure that the Commission is well prepared for and is effective in dealing with financial crime risks within the regulatory environment. Annette has been with the organisation for nearly 9 years and during this time she has gained significant experience and skills in all the areas required of the role, which include but are not limited to a technical working knowledge of AML/CFT risks, experience of delivering on major projects and strong working relationships with senior internal and external stakeholders.
The Group of International Finance Centre Supervisors (GIFCS) has become the international standard setter of regulatory standards in the Trust & Company Service Providers (TCSPs) arena. The GFSC was a central part of the GIFCS working group which drafted the standards, only recently finished. GIFCS priority is now on the implementation of this regulatory standard in all of the member jurisdictions, including implementing an assessment framework for all its members.
Therefore the Commission as a key member of GIFCS has needed to think on how best to support this work as well as to ensure the effective implementation of the standard locally. Strategically, the GFSC shall also play its part within the group of standard setters assessing the implementation in other jurisdictions. The Commission therefore needs to actively participate and manage its relationship with GIFCS. This will also include active participation in the work that GIFCS is doing with the Financial Action Task Force (FATF) in these areas. This is especially important when preparing to meet the challenges of a post-Brexit environment.
Neill Perera has taken a senior role within the Strategy and Planning team to manage and lead on these substantive GIFCS commitments and also to assist the Head of Financial Crime in providing bench strength support to deliver a good outcome for the MONEYVAL assessment and implement sensible frameworks for the ongoing assessment of AML/CFT risks.
Neill joined the GFSC in April 2005. During this time he has worked at a senior level, predominantly focusing on the supervision of TCSPs and latterly also audit and insolvency practitioners. During his time at the Commission his responsibilities have also briefly cut across into money services business, pensions and insurance supervision. His expertise, particularly in respect of TCSPs, has covered a variety of supervisory areas, most notably Client Money, AML/CFT and Corporate Governance.
The name of the current Professional Services which regulates TCSPs is being changed to Fiduciary and Business Services Supervision.
This is to reflect that pension regulation which is expected to come into force on the 5th April 2017 and the supervision of Bureaux will be carried out by this team.
Paul Garner has assumed the position of Head of this team. Paul joined the organisation in 2015, bringing with him many years of experience in management within the Gibraltar pension and investment advisory industries. Since then Paul has, amongst many other things, built and led the pension’s team and also assisted Policy in the development of the soon to be introduced, Financial Services (Pensions) Regulations 2017.
Finally, Audit and Insolvency, currently sitting within the previously named Professional Services team will be moving to the Prudential team. The Commission’s experience over the past year or so is that there are greater synergies between the GFSC’s Prudential focus and oversight of Audit and Insolvency practice than exist in the current Professional Services team.
These changes will not result in many variations on a day-to -day basis for the Commissions stakeholders.
Licensees contact points will remain the same and if there are to be any changes in individual relationships, firms will receive specific notification of these.