New Tricks for an Old Dog (Brexit again)

We are never too old to learn. Until a couple of weeks ago I thought that a "Reverse Greenland" was a difficult ice skating maneuver. Apparently it is one of the options being explored post Brexit, whereby Scotland, Northern Ireland and Gibraltar stay in the EU whilst the areas which voted out leave.

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Market Abuse

Certain types of behaviour, such as insider dealing and market manipulation, can amount to market abuse. Firms must have safeguards in place to identify and reduce the risk of market abuse and other financial crime.

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EU free movement not required for funds marketing - Morgan Lewis

Much attention has focused on access to the EU single market requiring acceptance of free movement of people but, in two important areas of the financial services sector, this is not the case.

The Alternative Investment Fund Managers Directive permits fund managers from outside the EU to opt-in to the regulatory regime under the Directive in order to market their funds to EU investors and to manage EU funds, either on a cross-border basis or via the establishment of branches in the EU. ‘Third country’ fund managers thus benefit from passporting rights and do not need to establish a presence in the EU in order to do so.

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4MLD amendments put banks at greater regulatory risk, say lawyers

The European Commission's proposed amendments to the Fourth Money Laundering Directive (4MLD) will put banks at risk of further attention from the Financial Conduct Authority, a law firm said. The availability of beneficial ownership information will be greater, but so will due diligence requirements.

In an amendment driven partly by the Panama papers, beneficial ownership registers established in the EU will have to be publicly accessible, which puts the onus on banks and other financial services firms to use them, despite their limitations, and face regulatory consequences if they fail to do so.

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European Union Referendum Result

Dear Licensee,

As you will be aware, on Thursday 23rd June 2016, a referendum was held to decide whether the United Kingdom should remain a part of the European Union or leave the European Union (EU).

The result of this referendum is now confirmed: the majority of people have voted in favour of leaving the EU.

However, the nature of the UK and Gibraltar’s future relationship with the EU is yet to be determined and is likely to be a lengthy process.

Therefore, it is important to note that business as usual will continue, and Gibraltar – together with the UK – remains part of the EU.

This means that consumers and depositors will still be protected by EU laws, and businesses will still be able to rely on access to the EU.

The Gibraltar Financial Services Commission will continue to work towards compliance with EU Directives and relevant legislation, and we will work closely with HM Government of Gibraltar at this time and over the coming months.

Our team stand ready to answer any queries you may have – please direct these to

GFSC Statement on the European Union Referendum result

Picardo’s defends Rock’s commitment to transparency

The United Kingdom needs to look at its own tax rules to ensure fairness, Chief Minister Fabian Picardo said this weekend as he defended Gibraltar commitment to transparency.

Mr Picardo made the comment during an interview with Dermot Murnaghan on Sky News on Sunday morning in the wake of the Panama Papers scandal and comparisons with Gibraltar.

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Contact Information

Gibraltar Association of Compliance Officers,

PO Box 1493, Gibraltar