The National Coordinator for AML/CFT has just issued the third and latest iteration of HM Government of Gibraltar's National Risk Assessment (NRA) for Money Laundering (ML), Terrorist Financing (TF) as well as Proliferation Financing (PF). An executive summary of the NRA has also been issued in tandem.
The NRA seeks to identify ML, TF and PF threats and vulnerabilities as they affect Gibraltar as a jurisdiction as well as public sector bodies and the private sector. The purpose of the NRA is to provide a realistic strengths-weaknesses analysis and to identify existing and future risks and map them effectively.
Businesses and professions (including Real Estate Agents (REAs) and High Value Dealers (HVDs) regulated by the OFT) must make use of these assessments to support their work to ensure that their systems of controls can prevent, detect and make the necessary disclosures to law enforcement agencies whenever ML, TF or PF is known to have occurred or when there is a suspicion of the same.
The OFT strongly encourages all REAs and HVDs to become acquainted with the relevant parts of the NRA that affect their businesses and to take note of the new risks set out therein to risk assess their business and update their AML/CFT policies and procedures as necessary. This is a legal obligation under the Proceeds of Crime Act 2015.