Our Approach to Financial Crime


It is the GFSC’s objective to prevent financial crime, therefore we are committed to meeting International standards on Anti Money Laundering and Combating the Financing of Terrorism. As the regulator of the financial services sector, we play a key role in Gibraltar’s overall approach to combating money laundering (ML) and terrorist financing (TF). To achieve this we apply a risk based supervisory approach to ML/TF risks to ensure that our supervision is focused, driven and separately accountable specific to the ML/TF threats.

Financial Crime is defined as activities that dishonestly generate wealth for those engaged in a criminal conduct, or activities that protect the proceeds of illicit activities. This includes money laundering, terrorist financing, bribery, corruption, fraud and market abuse. The primary objective of the Financial Crime supervisory team is the reduction of financial crime. This will be achieved by:

  • Enhancing the GFSC’s risk based supervisory framework for the ongoing supervision of money laundering and terrorist financing risk associated to the financial services industry.
  • Establishing a risk based supervisory framework for the ongoing supervision of financial crime risks to include bribery, fraud, etc.
  • Carrying out initial investigations of potential enforcement cases relating to financial crime, and support enforcement on any cases that involve financial crime.
  • Supervising firms and investigating potential breaches with respect to market abuse.
  • Establishing appropriate procedures for the dissemination of information relating to financial crime risks, market trends, international standards, expectations, etc.
  • Maintaining responsibility for the assessment of suspicious activity reports, raised internally and received from the Gibraltar Financial Intelligence Unit

The Financial Crime supervisory approach will assess firms compliance with AML/CFT requirements under the Proceeds of Crime Act, and will scrutinise the firms systems of controls and their effectiveness in identifying and mitigating financial crime.

The GFSC expects firms to:

  • Articulate an effective and proportionate risk based methodology, the rationale for such, and evidence the effectiveness of it
  • Apply a risk based approach in line with their risk appetite and tolerance.
  • Understand the risks associated to their type of activity
  • Employ and train staff to hold the skills and knowledge required to fulfil their functions
  • Implement a robust procedures for the disclosure of suspicious activity
  • Document its policies and procedures


Contact Us

Should you have any queries in respect to the GFSC’s approach to Financial Crime or the Anti-Money Laundering and Terrorist Financing requirements, you may contact the Financial Crime team on amlcft@gfsc.gi or on 20040283.



Proceeds of Crime Act Download
4MLD Download

Guidance Notes 

Guidance Notes Download
Eligible Introducer Certificate (F1) Download



Suspicious Activity Report Download
MLRO Annual Report Download
Compliance Report Download
Auditors Supplement Download



Slides - March 2017 MONEYVAL Presentation Download
Slides - September 2017 Financial Crime update Download


National Coordinator for Anti-Money Laundering and the Combatting of Terrorist Financing

National Risk Assessment Download
4MLD and amendments to POCA Download
NPOs and the risk of abuse from terrorist funding Download