CONTACT - Guernsey Chamber of Commerce
CONTACT - Guernsey Chamber of Commerce
CONTACT - Guernsey Chamber of Commerce
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the inclusion <strong>of</strong> accountants,<br />
auditors and insolvency practitioners<br />
(to the extent they were not already<br />
covered) within the regime.<br />
one may wonder whether criminal<br />
masterminds would contemplate<br />
laundering their ill-gotten gains<br />
through the medium <strong>of</strong> postage<br />
stamps but it is nevertheless a real<br />
risk, given the portability <strong>of</strong> the<br />
items themselves. the frequency<br />
<strong>of</strong> transactions involving bullion in<br />
<strong>Guernsey</strong> has brought the dealers<br />
into the aMl fold (as it is not just<br />
legitimate investors who have sought<br />
to protect their asset bases during the<br />
recent crisis), joining the remaining<br />
accountants, auditors and insolvency<br />
practitioners who were previously not<br />
covered. this “spreading <strong>of</strong> the net”<br />
is to be expected as criminals utilise<br />
new variants <strong>of</strong> old techniques to<br />
disguise the origins <strong>of</strong> their plunder.<br />
the new provisions are all<br />
designed to strengthen the regime<br />
and close a few <strong>of</strong> the potential<br />
loopholes that previously existed.<br />
there will, no doubt, be further<br />
changes to be made in future but it<br />
is to be expected that these will be<br />
directed at specific industries, or<br />
problems that arise, rather than any<br />
wholesale reforms <strong>of</strong> the system.<br />
Summary<br />
<strong>Guernsey</strong>’s aMl regime can, on the<br />
one hand, be viewed as a burden - an<br />
unnecessary barrier to doing business<br />
which would otherwise be done more<br />
swiftly and at less expense. However,<br />
this view ignores the reality <strong>of</strong> the<br />
global marketplace in which we<br />
operate and the framework in which<br />
the world’s leading economies are<br />
either operating or working towards.<br />
it also omits to consider the volume <strong>of</strong><br />
business that is directed to <strong>Guernsey</strong><br />
because <strong>of</strong> the strength and reputation<br />
<strong>of</strong> <strong>Guernsey</strong>’s regime and the desire <strong>of</strong><br />
many businesses to be seen to transact<br />
through recognised jurisdictions.<br />
care should be taken however,<br />
to ensure that having raised the<br />
bar to distance itself from some<br />
historically jaundiced views <strong>of</strong> the<br />
<strong>of</strong>fshore world, this is not detrimental<br />
to businesses in <strong>Guernsey</strong>.<br />
<strong>Guernsey</strong> has the infrastructure<br />
to attract further business and<br />
to maintain its position in the<br />
marketplace; the challenge for<br />
<strong>Guernsey</strong> in the future will be to<br />
ensure that it remains responsive,<br />
flexible, but also robust.<br />
www.guernseychamber.com | OCTOBER/NOVEMBER 2010 | <strong>CONTACT</strong> | 35