Time to review your approach as GFSC kicks off conflicts thematic review

1 April 2025 | UK & Europe | Articles

The Guernsey Financial Services Commission (GFSC) has kick-started their conflict of interest thematic review to a selection of fiduciary and investment licensees. Focusing on a variety of areas – firms are encouraged to conduct a thorough review and avoid being caught in the crossfire.

What is the conflict of interest thematic review covering?

The review is focused on assessing, and proposing enhancements to current practices and controls related to conflicts of interest. The review encompasses an initial questionnaire to collect data on existing practices, supported by on-site visits and interviews with key personnel. Areas under scrutiny include:

• Policies and Procedures
• Disclosure and Record Keeping
• Monitoring across different types of conflict
• Training
• Effectiveness of controls
• Practices around gifts and hospitality

The initial questionnaire submission is due to be completed by the 6th of May, with visits and interviews scheduled for later in 2025.

Why now?

The review comes in the wake of observations made during the MoneyVal review in 2024, and similar thematic reviews conducted in other jurisdictions, like Jersey.

Underscoring a desire to promote a culture of continuous improvement, the GFSC is keen to ensure transparency and accountability are the centre of firms’ approaches, and ultimately, that safeguarding the interests of clients remains a priority in maintaining market confidence.

Preparing for the thematic review – what should firms be doing now?

Firms should be taking the time now to review policies and procedures. While the questionnaire date is just around the corner, taking a proactive approach to reviewing and enhancing your own approach will stand you in good stead for conversations with the regulator – either as part of – or in the wake of the review.

Key areas to focus on are:

Policies: Are your COI policies clearly defined, and reflect current regulatory requirements?

Disclosures and records: Do you maintain accurate records of potential and actual COIs, and disclose in a timely manner to relevant stakeholders?

Ongoing monitoring and controls: How often do you monitor COI situations and test the effectiveness of existing controls.

Training: How often do employees receive training to raise awareness and understand the role they play?

Gifts and hospitality: Are your guidelines for accepting gifts and hospitality clear, understood and adhered to?

How we are supporting firms

We are actively supporting clients to ensure their approach to Conflicts of Interest meet regulatory standards, and protect their businesses. We can provide an independent review of your policies, disclosure and record-keeping processes, implement robust monitoring systems, and providing targeted training for your staff. Get in touch for a conversation with a member of the team.