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Ensuring Compliance,
Safeguarding Integrity
How ONYX can support regulated firms
ONYX works with regulated businesses to translate regulatory guidance into practical, proportionate action. We can support firms through policy and communications reviews, governance and board briefings, and targeted training to help teams understand regulatory expectations and apply them consistently. Our approach is pragmatic, aligned to Guernsey regulation, and tailored to the size and complexity of each organisation.
This page provides summaries of key GFSC regulatory updates and guidance. It does not include investment statistics summaries or sanctions information. These can be accessed directly for information purposes on the GFSC website at www.gfsc.gg.
20 January 2026 - Phishing attempt
The Guernsey Financial Services Commission is warning about a suspected phishing email that appears to come from the Commission using the domain “gfsc.gg.cliopost.com”. Recipients should not reply or click any links or attachments, and should instead forward the email to phishing@gfsc.gg. The Commission confirms its legitimate emails come from addresses ending “gfsc.gg”, and reminds firms to follow its Cyber Rules and Guidance (2021) by staying vigilant, maintaining appropriate cyber security software, applying IT updates promptly, and reporting significant cyber incidents to the Commission.
20 January 2026 - The Commission Launches Trainee Development Programme for School Leavers
The Guernsey Financial Services Commission has launched a four-year Trainee Development Programme for school leavers who want to start a salaried career in financial regulation while studying for a Degree in Applied Finance with the University of Exeter, without leaving Guernsey. Successful applicants will earn while they learn, receive structured training, mentoring and professional development, and rotate across two divisions to build analytical capability and a strong foundation for a public service career.
The programme is open to students with A Levels (or equivalent) in any subject at BBB or above, plus at least Grade 5 in GCSE English and Grade 6 in GCSE Mathematics. William Mason, the Commission’s Director General, said the initiative is designed to create accessible local career pathways and to show high-performing students that taking on significant debt to study away from home is not the only route.
12 January 2026 - Digital Finance Initiative Update
The Commission has reaffirmed its support for innovation in financial services through the Innovation Sandbox + Concierge, launched in October 2025 as part of Guernsey’s Digital Finance Initiative. The refreshed Sandbox provides a flexible, structured environment for firms to develop and introduce innovative products, technologies and business models, building on the former Innovation Soundbox.
Importantly, the Sandbox is no longer a mandatory route for all new or innovative firms, including virtual asset service providers. Firms can now proceed either through the Sandbox or directly via standard licensing, depending on what best suits their business model. This more proportionate approach is reflected in proposed updates to regulatory guidance.
The Sandbox is open now, and firms do not need to wait for the Digital Finance Initiative consultation to conclude before engaging with the Commission. Industry feedback is actively encouraged to help shape forward-looking regulation that supports innovation while maintaining Guernsey’s competitiveness.
16 December 2025 - New Regulatory Regime for Equity Release to Launch on 1 January 2026
The Guernsey Financial Services Commission has confirmed that a new regulatory regime for equity release will come into force on 1 January 2026, following consultation and amendments to the Lending, Credit and Finance (LCF) Law.
The regime will regulate equity release products, including lifetime mortgages and home reversion plans, allowing older homeowners to access value from their residential property without moving. Firms offering these products or related services will be required to be licensed under Part II of the LCF Law.
From January 2026, existing LCF licensees will be able to apply to extend their permissions, while new providers may apply for a full licence via the Commission’s Applications and Authorisations Portal. UK equity release providers authorised by the FCA may also benefit from an equivalence route, provided customers are advised by a locally licensed advisor.
To support market development, the Commission will apply a 50% reduction in application and annual fees for the first three years of the regime. Further details, including consultation papers and updated rules and guidance, are available on the Commission’s Equity Release webpage.
With the new equity release regime taking effect on 1 January 2026, firms should begin preparing well in advance to ensure a smooth transition.
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Assess scope: Confirm whether existing or proposed activities fall within the definition of equity release under the amended LCF Law, including lifetime mortgages or home reversion plans.
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Review licensing status: Existing LCF licensees should consider whether a variation of activities is required, while prospective providers should plan for a full licence application.
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Engage early with advisors: UK providers seeking to rely on equivalence should ensure advice arrangements involve a locally licensed advisor, as required.
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Prepare for applications: Familiarise teams with the Commission’s Applications and Authorisations Portal and review the updated Rules and Guidance.
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Factor in timing and costs: Build application timelines into business planning and take account of the temporary 50% fee discount available during the first three years of the regime.
Early engagement and preparation will help firms take advantage of the new framework while meeting regulatory expectations from day one.-
15 December 2025 - Thematic Review: Correspondent and intermediary relationships in the investment sector
The Commission has published a thematic review assessing how investment firms monitor and comply with the Handbook’s intermediary and correspondent relationship requirements. Based on 30 onsite visits and reviews of 244 regulated intermediaries, the Commission found that most firms demonstrate good risk understanding and appropriate controls, although a small number required risk mitigation programmes to strengthen weaknesses.
The review identified six key areas for improvement that all firms using these relationships should consider. The findings broadly support concerns raised by Moneyval in its 2024 mutual evaluation.
The GFSC will assess how firms implement the review’s findings through ongoing supervision and will undertake further sector outreach in 2026. Firms are also expected to actively re-assess, re-classify, and strengthen controls around intermediary and correspondent relationships. The thematic makes clear that passive reliance on Appendix C status is no longer sufficient. Firms should be able to evidence correct classification, low-risk justification, complete written confirmations, effective monitoring, and Board oversight of intermediary risk.
Firms should review all customers currently treated as regulated intermediaries to confirm they meet the section 9.8 criteria, including Appendix C status and a demonstrably low risk rating. Where these conditions are not met, relationships should be reclassified as correspondent relationships or underlying customers onboarded directly, with particular focus on sanctions exposure, non-Appendix C jurisdictions and misclassified structures.
Risk assessments for intermediary relationships should be strengthened to clearly document the purpose of the relationship, treatment of adverse media or regulatory issues, and underlying investor risks, ensuring only genuinely low-risk relationships remain classified as intermediaries.
Firms should refresh and validate written confirmations to ensure full compliance with Handbook rule 9.47, addressing common gaps such as control over accounts, life company undertakings and sanctions screening, with clear timelines and escalation where confirmations are overdue.
Central securities depositories (e.g. Euroclear and Clearstream) should generally be reclassified as correspondent relationships and subject to enhanced due diligence.
Intermediary relationships should be explicitly included in compliance monitoring programmes, with testing of risk ratings, Appendix C status and written confirmations, and clear evidence of escalation and remediation.
Finally, firms should enhance Board oversight by updating business risk assessments to reflect intermediary ML/TF/PF risks, improving management information on intermediary exposure and compliance outcomes, and ensuring the Board can demonstrate informed challenge.
Regulatory expectationThe Commission will assess how firms embed these actions through ongoing supervision, update the Handbook in line with Moneyval findings and international standards, and may impose risk mitigation programmes where progress is insufficient.
11 December 2025 - Digital Finance Initiative
The Guernsey Financial Services Commission has launched a Digital Finance Consultation Paper outlining proposals to support the adoption of digital finance across the Bailiwick’s financial services sector. The consultation aims to provide regulatory clarity on emerging technologies and proposes targeted changes to expand Guernsey’s Virtual Asset Service Provider (VASP) regime. Developed through extensive stakeholder engagement and analysis of international standards, the proposals seek to position Guernsey as a trusted and innovative digital finance hub while maintaining regulatory integrity. Key measures include enabling tokenisation of investment schemes, clarifying the treatment of tokenised securities, broadening and simplifying the VASP regime, introducing a stablecoin framework, supporting digital asset custody, and promoting the use of technology to enhance financial crime compliance. The consultation is open until 6 March 2026.
9 December 2025 - GFSC Feedback Statement on Anti-Greenwashing Guidance and Code of Corporate Governance
Strengthening Transparency and Governance in Guernsey’s Financial Sector
The Guernsey Financial Services Commission (GFSC) has published a Feedback Statement following its consultation on two key initiatives that affect regulated firms: a new Anti-Greenwashing Guidance Note and updates to the Finance Sector Code of Corporate Governance. Both measures are designed to clarify expectations around sustainability communications and board-level oversight of environmental risks.
The Anti-Greenwashing Guidance makes explicit that all licensed entities must ensure any reference to environmental sustainability characteristics in their communications is fair, clear, not misleading, and accurately reflects the underlying attributes of the product or service. This guidance reinforces obligations already embedded in the Minimum Criteria for Licensing and comes into force on 1 February 2026. Alongside this, amendments to the Finance Sector Code of Corporate Governance broaden board responsibilities around environmental sustainability, extending oversight beyond climate-related risks to include a wider range of environmental considerations such as biodiversity. These changes align governance expectations with evolving global best practice and reflect feedback from industry respondents during the consultation process.
Both the Anti-Greenwashing Guidance and the revised Code provisions will apply from 1 February 2026, providing a clear regulatory framework that supports credible sustainability practices while recognising that well-managed firms are already meeting these standards.
The Guernsey Financial Services Commission has published a feedback statement confirming the introduction of Anti-Greenwashing Guidance and updates to the Finance Sector Code of Corporate Governance. Together, these changes clarify regulatory expectations around how firms communicate environmental sustainability and how boards oversee environmental risks. The focus is on transparency, accuracy and governance, rather than the creation of new sustainability obligations. The guidance reinforces existing principles under the Minimum Criteria for Licensing and aligns Guernsey with evolving international regulatory standards. Both the Anti-Greenwashing Guidance and the updated governance provisions will take effect from 1 February 2026.
The Anti-Greenwashing Guidance applies to all GFSC-licensed entities and covers any reference to environmental or sustainability characteristics in communications. Firms should take proportionate steps to ensure that environmental claims are fair, clear and not misleading, and that they accurately reflect the underlying product or service.
Key actions include:
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Reviewing websites, marketing materials and client communications for environmental claims
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Ensuring sustainability statements are accurate, evidence-based and capable of being substantiated
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Introducing appropriate internal review or sign-off for ESG or environmental messaging
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Amending or removing claims that cannot be properly supported
The guidance applies regardless of whether sustainability is a core part of the firm’s business model.
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Updates to the Finance Sector Code of Corporate Governance extend board-level oversight beyond climate risk to broader environmental sustainability considerations, including biodiversity and natural capital. Boards are expected to consider environmental risks as part of their overall governance and risk management responsibilities, in a manner proportionate to the size, nature and complexity of the business.
Boards and senior management should:
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Integrate environmental sustainability risks into governance and risk frameworks
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Ensure appropriate reporting and discussion at board or committee level
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Keep oversight under regular review as business activities or risk profiles change
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Maintain clear documentation of how environmental risks are considered
This is an extension of existing good governance practice, not a standalone ESG regime.
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All GFSC-licensed firms
Firms should review environmental claims in communications and ensure governance frameworks capture relevant environmental risks in a proportionate way. Each firm should apply the guidance in a way that reflects its business model and regulatory footprint.
Investment funds and fund managers
Environmental characteristics described in prospectuses, offering documents or investor materials must be accurate, transparent and supported by clear methodologies.
Fiduciary and corporate service providers
Marketing and client-facing materials should be reviewed carefully, particularly where sustainability language is used in service descriptions or group branding.
Banks and insurers
Boards should ensure environmental sustainability risks are considered alongside other strategic and operational risks, with appropriate oversight and reporting.The Anti-Greenwashing Guidance and the updated Finance Sector Code of Corporate Governance will apply from 1 February 2026.
While the effective date allows time for preparation, firms are expected to take reasonable steps in advance to understand how the guidance applies to their business.
Practical preparation steps include:
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Conducting a gap analysis of existing communications and governance arrangements
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Updating internal policies or procedures where needed
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Briefing boards, senior management and relevant teams
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Ensuring documentation and oversight arrangements are in place
Early preparation will support smoother implementation and regulatory engagement.
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