For Guernsey firms
Compliance software for Guernsey firms, built on the Commission’s own rules and Handbook.

- The Commission watched for youIts news and consultations pages read by the Monitor, each publication logged once with its stage and dates.
- Policies read against the rulesInspector checks your library against the Guernsey regimes you switch on and raises findings with drafted fixes.
- The record kept as you goEvery finding and approval carries a named person and a date, ready for the Commission.
Today
- The sector rules, the Handbook on Countering Financial Crime and the Commission’s Dear CEO letters change, and most compliance tools are written for the UK or the EU.
- When the Commission visits, the answer to “what did you do about it” is spread across inboxes and folders.
With Amoreg
- The Commission watched for you. Its news and consultations pages read by the Monitor, each publication logged once with its stage and dates.
- Policies read against the rules. Inspector checks your library against the Guernsey regimes you switch on and raises findings with drafted fixes.
- The record kept as you go. Every finding and approval carries a named person and a date, ready for the Commission.
Follow one through. A GFSC letter, from posted to decided.
Switch on the regimes you are held to. Amoreg watches their sources and keeps every publication until someone decides.
Three ways to do it. One that keeps the file.
Compare AmoregGeneral descriptions of each approach. Some assistants add connectors, citations and enterprise controls; we are happy to compare Amoreg with the tools you use today.
For Guernsey firms: what it is and what regulators expect.
Who regulates financial services in Guernsey
The Bailiwick of Guernsey, which includes Alderney and Sark, is a self-governing Crown Dependency with its own financial services law. It is not part of the United Kingdom or the European Union. The UK’s Financial Conduct Authority has no remit in the Bailiwick, so a compliance tool built around FCA or EU rules does not describe what applies to a Guernsey firm.
The Guernsey Financial Services Commission was established under the Financial Services Commission (Bailiwick of Guernsey) Law, 1987. It licenses investment business and funds under the Protection of Investors Law, 2020, banks under the Banking Supervision Law, 2020, insurers under the Insurance Business Law, 2002, fiduciaries under the Regulation of Fiduciaries, Administration Businesses and Company Directors, etc. Law, 2020, and lenders and credit providers under the Lending, Credit and Finance Law, 2022. Its regulatory laws are Bailiwick laws, so its supervision extends across Guernsey, Alderney and Sark.
Which rules a licensee follows
Each sector has its own rules and guidance. Fiduciary licensees follow conduct, client asset, record keeping and resourcing rules. Insurers and insurance managers follow conduct, solvency, governance and reporting rules. Investment business and authorised or registered schemes answer to the Protection of Investors Law and the Collective Investment Scheme Rules.
Two sets of expectations apply to every licensee. The Finance Sector Code of Corporate Governance sets principles for boards. The Commission does not routinely ask for an annual assurance statement of compliance, but it can require one from a firm. The Commission’s cyber security rules and guidance expect board-owned cyber security based on the NIST functions.
For financial crime, the obligations sit in Schedule 3 to the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999. The rules and guidance are in the Commission’s Handbook on Countering Financial Crime (AML/CFT/CPF), which covers risk assessment, due diligence, monitoring and reporting. Suspicious activity reports go to the Bailiwick’s Financial Intelligence Unit, not to the Commission. Data protection is overseen by the Office of the Data Protection Authority under the Data Protection (Bailiwick of Guernsey) Law, 2017, and the Guernsey Registry keeps the registers of companies and of beneficial owners of legal persons.
What changes, and what to watch
A consultation from the Commission is the earliest sign of a change to a handbook, a code or a sector’s rules, and the stage at which a firm can respond. Open and closed consultations, discussion papers and feedback statements from May 2025 onwards are on the Commission’s Engagement Hub. A firm that reads those pages only when someone mentions them finds out late.
The Commission also writes to chief executives in Dear CEO letters, for example on technology risk. They are not rules, but they show where the Commission is looking; read each letter on the Commission’s own site for what it asks.
MONEYVAL’s on-site visit to Guernsey took place in April 2024, and its fifth-round mutual evaluation report was published on 10 February 2025. Its findings are a useful guide to what supervisors and firms will prioritise, and a reason to keep evidence of how controls work in practice, not only the policy wording.
How a Guernsey firm turns a change into evidence
When the Commission consults or updates a rule or the Handbook, the work has four steps. Someone reads the publication and decides whether it applies to the firm. If it does, the policies it touches are listed and compared with the new wording. Each gap becomes an action with an owner and a date. When the action is done, the approval is filed next to the publication that caused it.
Each step is simple. The difficulty is doing all four, every time, for every publication, and being able to show it later. A spreadsheet of changes and a shared folder can hold the record, but only while one person keeps both up to date. This is where software earns its place: it makes the trail the by-product of the work, not an extra task at the end of the quarter.
Firms that also operate elsewhere
Many Guernsey firms have a group in Jersey, the Isle of Man, the United Kingdom or the European Union. The rules do not merge. Guernsey law and the Commission’s rules apply to the Guernsey entity, and the other regulator’s rules apply to the entity in its territory. A compliance record that mixes them makes it hard to show which standard a decision was tested against.
The practical answer is to keep the record by regulator, and to name the regulator and the rule against every finding. The Jersey page and the page for trust and corporate service providers cover the same ground for their own rules.
What compliance software has to do for a Guernsey firm
In practice the software has five jobs. Watch the Commission and the other bodies the firm answers to, and record what they publish. Hold the Guernsey rules and Handbook as the standard, with the UK and the EU only where the firm also operates there. Check the firm’s own policies against them. Run reviews and tests on a schedule, with a named person at each gate. Keep the record, so that the answer to “what did you do about it” is on file.
The record is the part a supervisor asks for. A general AI assistant can explain a rule, but it does not watch the Commission, remember what was decided last quarter or show who approved a change. A policy library that nobody reads against the rules gives the same result: the document exists, and no one can show it is current.
How Amoreg runs it
The Monitor reads the Commission’s news page and its consultations page. Each publication is recorded once with its source address, stage and date, then assessed against the policies it touches. Whether a publication applies to your firm is a person’s decision, recorded with their name.
The library carries the Commission’s Handbook on Countering Financial Crime, fiduciary rules, cyber security rules and corporate governance code as regimes, each with its headline controls. Inspector reads your policy library every week against the regimes you switch on. It stays quiet about documents that are fine and raises a finding, with a drafted fix, where one falls short. A person approves or dismisses each finding, and the file keeps who decided and when.
Amoreg supports the compliance function; it does not replace the money laundering reporting officer or the compliance officer, and it does not decide for them. Trust and corporate service providers should also read the page for those firms, which covers the Isle of Man and Jersey alongside Guernsey.
Amoreg Limited is a Guernsey company, so these are the rules of its own island, and its library holds them beside those of Jersey and the Isle of Man. The page on compliance software for the Channel Islands, linked below, sets Guernsey and Jersey side by side.
Sources
- Guernsey Financial Services CommissionThe Commission’s home page, with its laws, handbooks, guidance and enforcement pages.gfsc.gg
- Guernsey Financial Services Commission: Handbook on Countering Financial CrimeRules and guidance on AML/CFT/CPF.gfsc.gg/commission/financial-crime/handbook-on-countering-financial-crime-AML/CFT/CPF
- Guernsey Financial Services Commission: consultationsConsultation announcements and feedback statements.gfsc.gg/news/consultations
- Guernsey Financial Services Commission: Engagement HubOpen and closed consultations and discussion papers from May 2025.engagementhub.gfsc.gg
- Financial Intelligence UnitWhere suspicious activity reports for the Bailiwick are made.guernseyfiu.gov.gg
- Office of the Data Protection AuthorityData protection law and guidance.odpa.gg
Questions Guernsey firms ask.
Who regulates financial services in Guernsey?
The Guernsey Financial Services Commission. It licenses and supervises fiduciaries, investment business and funds, banks, insurers and lenders across the Bailiwick, and supervises them for AML/CFT/CPF.
What is Guernsey compliance software?
Software that helps a Guernsey licensee meet its own regulatory duties: watching the Commission, checking policies against its rules and the Handbook, running reviews and approvals, and keeping the record. It is distinct from client screening tools.
Which AML rules apply to Guernsey firms?
Schedule 3 to the Criminal Justice (Proceeds of Crime) (Bailiwick of Guernsey) Law, 1999, with the Commission’s Handbook on Countering Financial Crime (AML/CFT/CPF), which carries the rules and guidance on risk assessment, due diligence, monitoring and reporting.
Does the FCA regulate Guernsey firms?
No. Guernsey is a Crown Dependency outside the United Kingdom and the European Union. A firm that does business in both places must meet each regulator’s rules.
Where are suspicious activity reports made in Guernsey?
To the Bailiwick’s Financial Intelligence Unit, not to the Commission.
Does Amoreg replace the compliance officer or MLRO?
No. Amoreg watches the Commission, reads your policies against the rules and keeps the record, but a named person decides every finding and approval.
The rules firms like yours answer to.
Enable them and the Monitor watches their issuers, while Inspector reads your library against each one.
- GFSC Handbook on Countering Financial Crime (AML/CFT/CPF)The Bailiwick's AML/CFT/CPF rules and guidance for financial services businesses and prescribed businesses, issued under the Criminal Justice (Proceeds of Crime) regulations.Guernsey · 8 controls
- GFSC Fiduciary Rules and GuidanceConduct, client asset, record keeping and resourcing rules for fiduciary licensees.Guernsey · 5 controls
- GFSC Cyber Security Rules and GuidanceBoard-owned cyber security based on the NIST functions, for all licensees.Guernsey · 5 controls
- GFSC Finance Sector Code of Corporate GovernancePrinciples for the boards of all Guernsey licensees, with an annual confirmation of compliance.Guernsey · 5 controls
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