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Behind the scenes of a MONEYVAL Interview: A First-Hand Account

Behind the scenes of a MONEYVAL Interview: A First-Hand Account

3 July 2024

We’d always known they might pick additional businesses beyond what we’d prepared for, but you never know for sure. And sure enough, one of my clients – an international lending business – got the nod. I got the call from the Commission, "One of your other clients has been selected. Can Tracy now attend for Client A while you do the interview for Client B?"

The team at Redwood, had been working closely with our clients for such a scenario. We had Tracy handling one client, and suddenly, we had another one in the mix. It was time for some intensive preparation.

The first task was to have a call with the MD of our client. We had a two-week window before the MONEYVAL interview. The GFSC offered us a mock interview via Teams, which was incredibly useful. It helped us anticipate the line of questioning and understand the likely dynamics of the interviewing panel.

I had several detailed meetings with the MD, ensuring we were completely up to speed on all the latest financial crime themes and updates. Helpfully, Redwood had acted for the client since incorporation. As such, I knew there were no legacy matters and both the MD and I had worked together to build the existing Financial Crime control framework for the business. We were confident there would be no surprises that could catch us off guard.

When the day of the visit arrived, I felt a mixture of nerves and excitement. I wasn’t just representing my client or Redwood; I was representing Guernsey. The pressure was on but we were positive that we had been thorough in our preparation.

The interview was to be held at St Pierre Park Hotel and we were instructed to arrive 30 minutes early to register with the GFSC team. They escorted us to the bar area – while a pint would've been tempting, I stuck to a trusty cup of tea. My client and I went over some final notes and I could feel the nervous energy building.

As we were led to the interview room, we were greeted by a panel of three – a relief, considering we’d been told it could be up to seven. The panel included a representative from the secretariat, the Czech National Bank, and the Maltese FIU.

The interview was professional and punctual, starting with pleasantries before delving into the core questions. Most queries were anticipated, thanks to the GFSC documents and our mock interview. My client's unique business model was under scrutiny, particularly regarding risk controls, the onboarding process, and the roles of legal representatives and internal compliance frameworks. They also asked about Guernsey's regulatory framework, interactions with the GFSC and FIU, high-risk clients, PEPs, SAR reporting processes, specific SAR cases, how transactions were undertaken and where did we see the risks of terrorism and proliferation financing

And then, just like that, it was over. The hour flew by, leaving us almost euphoric as we exited the room. We felt we’d aced it, representing not just our client, but the industry and the island itself. It was a positive and open dialogue with professionals, and we left feeling confident that nothing negative had come up.

The final part of the process involved debriefing with the GFSC team, discussing any unexpected questions or concerns.

Being a small part of the overall process was an honour and it shone a further light onto the massive efforts made by so many people to ensure that Guernsey gave as good an account of itself as possible.

What’s left now is for the MONEYVAL team to issue a draft report for the Guernsey authorities, expected in July, with the finalisation process likely extending to early 2025 at the European Council plenary.

Reflecting on the immense effort and work put in by everyone involved, it was clear that we were in a strong position. It left me with a sense of pride and anticipation for a favourable report.

It was one of those calls that startles you out of your routine: “MONEYVAL have selected one of your clients.” The Commission had always said there'd be between 30 and 60 businesses up for inspection by MONEYVAL, some would be based on those that Guernsey had put forward and some would be at random.

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