--- title: "Gibraltar (GIB) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/gibraltar/ source_html: /jurisdictions/gibraltar/index.html description: "Financial integrity intelligence for Gibraltar (GIB): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T17:53:23Z content_sha256: 9f59ed9b0f71e82e22bfcf7e43fcd7237f9001d7f462e23e8c7feddf5a592007 generator: "fe-fleet/md-twin@1.0" --- # Gibraltar (GIB) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Gibraltar GIB Domains covered 8 of 8 Sources 192 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Clean Tier: B Risk direction: Decreasing Enablement vs enforcement: Mixed Gibraltar (British Overseas Territory) runs its own AML/CFT/CPF regime under the Proceeds of Crime Act 2015, Terrorism Act 2018 and Sanctions Act 2019, supervised by the GFSC and GFIU. More It was removed from FATF increased monitoring in Feb 2024 and the EU high-risk list in June 2025, but retains structural exposure via its offshore-facing insurance, gaming and DLT/crypto sectors and a historically porous Spain frontier. Key deficiencies - Sanctions imposed by supervisors historically assessed as not proportionate or dissuasive across the majority of AML/CFT cases - Weak outgoing mutual legal assistance activity relative to Gibraltar's cross-border exposure to complex international ML cases - No PF-related targeted financial sanctions asset freezes have ever been executed, alongside low private-sector (especially DNFBP) awareness of proliferation-financing TFS obligations - Complex ownership structures and trusts remain a weak spot for beneficial-ownership identification among banks and some other reporting entities Recent developments (18m) - FATF/MONEYVAL removed Gibraltar from the 'Jurisdictions under Increased Monitoring' grey list on 23 February 2024, with MONEYVAL closing further reporting after a follow-up re-rating exercise - European Commission delisted Gibraltar from the EU list of high-risk third countries for AML/CFT purposes on 10 June 2025 - OFSI issued a wind-down General Licence (Feb 2026) for Maritime Mutual Association Limited ('Maritime Mutual Gibraltar'), a Gibraltar-domiciled marine insurer with Russia-sanctions exposure - UK-Gibraltar transitional financial-services market access arrangements extended by a further 12 months to 16 December 2026 pending finalisation of the long-term Gibraltar Authorisation Regime (GAR) Brief ## Lead signal #### Lead Signal Gibraltar presents, as at November 2026, a mature and autonomously legislated anti-money-laundering, counter-terrorist-financing and sanctions architecture whose current standing position is confirmed across four firm-level enforcement actions concluded in the 2023 to 2025 period and a formal exit from enhanced monitoring by the regional mutual-evaluation body. The Gibraltar Financial Services Commission imposed penalties on Tap Global Limited of 150,000 pounds for suspicious-activity-reporting failures, on Blacktower Financial Management (International) Limited of 294,479 pounds for customer due diligence and sanctions-screening deficiencies, and on Alvar Financial Services Limited and Argon Financial Limited of 186,038.52 pounds and 71,281 pounds respectively for control and management failures. In parallel, Gibraltar achieved a rating of Largely Compliant or Compliant on all forty FATF Recommendations following a 2024 re-rating of Recommendation 36, bringing the enhanced follow-up procedure maintained by the regional evaluation body to a close. Read together, the enforcement record and the compliance re-rating describe a jurisdiction where the architecture is not merely declaratory: obligations under the Proceeds of Crime Act 2015 are actively tested against firms spanning crypto-asset, payments and investment-management activity, and the supervisory body has shown a willingness to levy penalties running into the hundreds of thousands of pounds. Read full brief #### Lead Signal Gibraltar presents, as at November 2026, a mature and autonomously legislated anti-money-laundering, counter-terrorist-financing and sanctions architecture whose current standing position is confirmed across four firm-level enforcement actions concluded in the 2023 to 2025 period and a formal exit from enhanced monitoring by the regional mutual-evaluation body. The Gibraltar Financial Services Commission imposed penalties on Tap Global Limited of 150,000 pounds for suspicious-activity-reporting failures, on Blacktower Financial Management (International) Limited of 294,479 pounds for customer due diligence and sanctions-screening deficiencies, and on Alvar Financial Services Limited and Argon Financial Limited of 186,038.52 pounds and 71,281 pounds respectively for control and management failures. In parallel, Gibraltar achieved a rating of Largely Compliant or Compliant on all forty FATF Recommendations following a 2024 re-rating of Recommendation 36, bringing the enhanced follow-up procedure maintained by the regional evaluation body to a close. Read together, the enforcement record and the compliance re-rating describe a jurisdiction where the architecture is not merely declaratory: obligations under the Proceeds of Crime Act 2015 are actively tested against firms spanning crypto-asset, payments and investment-management activity, and the supervisory body has shown a willingness to levy penalties running into the hundreds of thousands of pounds. The standing core of this architecture rests on the Proceeds of Crime Act 2015, which established the Gibraltar Financial Intelligence Unit and sets out, in Part III, customer due diligence, record-keeping and suspicious-activity-reporting duties, underpinned by criminal penalties for money-laundering offences of up to fourteen years imprisonment. Firms report suspicion of money laundering, terrorist financing or proliferation financing to the Financial Intelligence Unit without delay once a money-laundering reporting officer determines the grounds for suspicion are satisfied, subject to a consent and sixty-working-day moratorium regime where consent is withheld. These are not new measures: they are the settled operating rules against which both the 2025 enforcement actions and the rising volume of suspicious-activity reports described below are now measured. #### Other Developments Suspicious-activity reporting volumes rose sharply in 2025. The Financial Intelligence Unit recorded more than 5,800 suspicious-activity reports for the year, a 17.5 percent increase on the prior year's total of 4,950, with the virtual-asset-service-provider sector contributing a near-doubling of its own disclosures. Separately, Financial Intelligence Unit statistics for the second quarter of 2025 show 194 requests for consent to proceed despite a suspicion of money laundering, of which 166, or 86 percent, were granted. The penalty architecture underpinning supervisory enforcement is set out in the Supervisory Bodies (Powers etc.) Regulations 2017. A supervisory body may impose an administrative penalty on a relevant person for breach of Proceeds of Crime Act obligations up to the higher of twice the benefit derived or 1 million euros for most relevant persons, rising to 5 million euros or 10 percent of total annual turnover for credit and financial institutions. A possible successor instrument dated 2025 carrying a comparable 1 million euro cap has been identified as a research lead but has not yet been independently confirmed as superseding the 2017 Regulations. An Unexplained Wealth Order regime took effect in October 2024. Amendments to the Proceeds of Crime Act allow the Supreme Court to require an individual, typically a politically exposed person or a person suspected of serious crime, to explain how property worth more than 50,000 pounds was acquired where known lawful income appears insufficient; making a false statement in response carries a penalty of up to two years imprisonment. #### Cross-Monitor Connections The virtual-asset dimension of Gibraltar's suspicious-activity-reporting increase, in which the sector's disclosures nearly doubled, connects directly to the jurisdiction's standing digital-asset regulatory perimeter and merits attention from monitors tracking crypto-sector money-laundering exposure. The Unexplained Wealth Order regime and its politically-exposed-person framing connect to monitors tracking conflict finance and state-capture typologies, since the explanatory-order mechanism is the principal domestic tool available where suspect wealth cannot otherwise be traced to a predicate offence. The rise in suspicious-activity-report volume alongside an 86 percent consent-grant rate for the second quarter of 2025 may also be of interest to monitors assessing the throughput and capacity of financial-intelligence-unit consent regimes more broadly. #### Outlook Gibraltar's compliance posture, having just closed out enhanced monitoring by the regional evaluation body, now faces its sixth-round mutual evaluation, with an on-site visit provisionally scheduled for October 2027 and a Plenary discussion expected around May 2028; both dates remain provisional and should be treated as indicative rather than fixed. A consultation on enhanced customer due diligence obligations aligned with updated FATF Recommendation 16, targeting virtual-asset-service providers and correspondent banking, has been signalled by the supervisory body but carries no confirmed timetable and rests on a single source, so its shape and timing should be treated as unresolved rather than settled. The rising trajectory of suspicious-activity-report volumes, if sustained, points toward continuing pressure on the Financial Intelligence Unit's consent and triage capacity, a pattern worth monitoring through subsequent statistical releases rather than assuming to continue unchanged. Earlier periodic briefs (6) Periodic updates below are dated within the scope of the expert review (as at 27 Oct 2026). 25 Oct 2026 · fim-2026-10-25 Expert reviewed #### Lead Signal Gibraltar's standing in two architecture-level reviews moved in the same window. MONEYVAL re-rated Gibraltar from Partially Compliant to Largely Compliant on FATF Recommendation 36, which covers the application of international mutual-legal-assistance instruments, and terminated the enhanced follow-up procedure that had run under the fifth-round evaluation process since the December 2019 mutual evaluation report. Out of the forty FATF Recommendations, Gibraltar is now reported at twenty-three rated Compliant and seventeen rated Largely Compliant. In parallel, Gibraltar's domestic sanctions-enforcement architecture gained a new civil track: the Sanctions Civil Enforcement Regulations 2026 and the Sanctions Civil Enforcement Authority (Designation) Order 2026, both made 9 September 2026 under the enabling Sanctions (Amendment) Act 2026 of 9 July 2026, give a designated civil enforcement authority power to impose a monetary penalty on the balance of probabilities for a breach of a sanctions prohibition, recoverable as a civil debt, running alongside the existing criminal offence route. #### Other Developments A new digital-asset entity entered the GFSC-supervised population. Revolut Global Digital Assets Limited, a newly established Gibraltar entity, obtained a GFSC DLT Provider licence permitting virtual-asset order execution, custody and staking, announced 19 October 2026. The licence expands the population of GFSC-supervised virtual asset service providers that fall within Gibraltar's Proceeds of Crime Act 2015 travel-rule and AML perimeter. Gibraltar's AML/CFT architecture rests on the Proceeds of Crime Act 2015, with GFSC and GFIU as the supervisory and financial-intelligence structure assessed by MONEYVAL. That structure is reported unchanged in its substantive form; the movement is in the MONEYVAL rating applied to it, not in the underlying statute. Gibraltar continues to apply UK and EU-derived sanctions regimes alongside UN Security Council measures , and the new civil penalty track sits on top of that existing designations architecture rather than replacing it. #### Cross-Monitor Connections The Revolut licensing development and the associated resumption of electronic-money and payments onboarding touch the payments-sector monitor directly, since the new entity combines a digital-assets permission with a payments business presence under the same Gibraltar regulatory umbrella. The sanctions civil-enforcement track is architecture-level and jurisdiction-agnostic in its design, lowering the evidentiary bar for enforcement generally rather than targeting any single sector; firms assessed elsewhere for Gibraltar sanctions exposure should treat the civil route as a parallel channel to the criminal offence that already existed. No conflict-finance, enabler-jurisdiction, or beneficial-ownership findings specific to Gibraltar were located; this reflects a narrow research window and pooled search budget rather than a confirmed absence of activity in those areas. #### Outlook The substantive content of the Sanctions Civil Enforcement Regulations 2026, including penalty quanta and procedure, is assessed at Probable confidence pending consolidated GFSC/GFIU civil-penalty tariff guidance under the Sanctions Act 2019, and that detail will materially shape how the civil track is used in practice once tested. Gibraltar's re-rating on R.36 and termination of enhanced follow-up leaves it positioned among a small group of jurisdictions rated Compliant or Largely Compliant across the full FATF Recommendation set, a position that bears watching for whether it holds through any subsequent full re-evaluation cycle. 18 Oct 2026 · fim-2026-10-18 Expert reviewed #### Lead Signal MONEYVAL's follow-up report, published 9 October 2026, re-rated Gibraltar from Partially Compliant to Largely Compliant on FATF Recommendation 36, closing enhanced follow-up under the fifth evaluation round. Gibraltar now holds 23 Compliant and 17 Largely Compliant ratings out of 40 FATF Recommendations. This is a structural improvement in Gibraltar's assessed compliance architecture rather than an isolated enforcement incident, and it sits against a regime, POCA as amended, the Sanctions Act 2019, the Terrorism Act 2018 and the Crimes Act 2011, supervised by the Gibraltar Financial Services Commission with the Gibraltar Financial Intelligence Unit as the SAR and STR recipient, that is unchanged in its basic architecture this cycle. Gibraltar's next MONEYVAL technical-compliance submission is due March 2027, with an onsite visit in October 2027 and plenary discussion in May 2028, under Gibraltar's own standalone FATF-style assessment track, autonomous of the EU AML Package. #### Other Developments A civil sanctions-enforcement track has been established. Gibraltar enacted the Sanctions (Amendment) Act 2026 and Sanctions Civil Enforcement Regulations 2026 (LN.2026/332, LN.2026/333), designating a Sanctions Civil Enforcement Authority with power to impose a monetary penalty on a person under the Sanctions Act 2019. This runs in parallel to, but is legally distinct from, the UK's own single Sanctions List consolidation. Gibraltar's crypto travel-rule instrument has been revoked without a located successor. The Proceeds of Crime Act 2015 (Transfer of Virtual Assets) Regulations 2021, in effect since March 2021, was revoked by LN.2026/134 effective 15 July 2026; the text of any successor instrument governing virtual-asset transfer reporting has not been retrieved, leaving a near-term coverage gap for AML obligations on virtual-asset transfers pending clarification. Gibraltar's tokenisation commercial ecosystem continues to develop. Bullish Group received GFSC approval to trade tokenised securities around late June 2026, and the Protected Cell Companies (Amendment) Act 2026, enacted 9 July 2026, creates a bespoke regime permitting tokenised Experienced Investor Fund cell shares; Gibraltar's fintech sector shows 452 million dollars in cumulative venture and private-equity funding across 32 companies as of September 2026, though no GFSC primary-source notice formalising the Bullish Group approval was independently retrieved this cycle, and the finding rests on the company's own announcement. #### Cross-Monitor Connections The revocation of Gibraltar's crypto travel-rule instrument without a located successor is a direct architecture-level signal for any crypto or digital-asset monitor tracking Gibraltar's virtual-asset AML posture, since the gap concerns the reporting infrastructure for virtual-asset transfers specifically. The tokenisation commercial developments, the Bullish Group approval and the Protected Cell Companies Act, connect to payments and digital-infrastructure monitoring tracking Gibraltar's fintech and DLT commercial landscape. The new sanctions civil-enforcement track, distinct from the UK's consolidated list, is relevant to any monitor tracking divergence between UK and Gibraltar sanctions implementation as the two jurisdictions' frameworks continue to run in parallel rather than as a single regime. #### Outlook Gibraltar's compliance trajectory under FATF Recommendation 36 is now improving, with the next formal assessment milestones, technical-compliance submission in March 2027, onsite visit in October 2027, and plenary discussion in May 2028, setting the schedule for whether this improvement is sustained across the broader 40-Recommendation framework. The most immediate open item is the content of the successor instrument to the revoked virtual-asset transfer regulations; until that text is identified, the practical AML coverage for virtual-asset transfers in Gibraltar remains unconfirmed. 6 Oct 2026 · fim-2026-10-06 Expert reviewed #### Lead Signal Gibraltars anti-money-laundering architecture this cycle resolves into a clearer, more granular picture of how the Proceeds of Crime Act 2015 (POCA) actually constrains customer due diligence at the point where theory meets practice. The headline finding is structural rather than episodic: Gibraltar has no numerical electronic-money purse-limit derogation from simplified due diligence (SDD), and whatever SDD latitude section 16 of POCA otherwise allows is overridden by section 16(5) geographic-risk precedence under the 2025 National Risk Assessment (NRA v1.3). The practical effect is unambiguous. A regulated entity can never treat Spain as a Low Risk country, and no customer with a residency, nationality or economic-activity connection to Spain may be given SDD, regardless of product type or transaction value. Morocco sits under a parallel constraint, with funds from either jurisdiction required to be categorised as high risk and subjected to additional risk-based controls. This is not a blanket prohibition on serving Spain-connected customers, nor does it mandate automatic enhanced due diligence for every such relationship; it is a floor beneath which the risk rating cannot fall, which is a materially different and more precise instrument than either extreme would suggest. The second pillar of this weeks lead signal is the commencement of the Funds (Transfer) Regulations 2026 (LN 2026/134) on 15 July 2026, which revokes the onshored text of Regulation (EU) 2015/847 and replaces it with a travel-rule regime that, notably, extends to virtual asset transfers. Payment service providers and virtual asset service providers alike must now attach originator and beneficiary information to transfers, verify that information before execution, and retain records for five years; a reduced-information threshold applies to unlinked transfers up to EUR 1,000 equivalent. This is an architecture-over-incident development in the fullest sense: it does not respond to a single enforcement failure but resets the entire information-accompaniment baseline for funds movement through Gibraltar, fiat and virtual alike. #### Other Developments The PEP continuing-obligations regime diverges from UK practice in a way firms applying UK Money Laundering Regulations logic to Gibraltar accounts could easily miss. Under POCA sections 20A, 20B and 20(2), the test for a politically exposed person is the prominent public function itself, with no foreign/domestic distinction, and once a PEP leaves office a Gibraltar relevant financial business must continue risk-sensitive measures for at least twelve months, a duty that extends to family members and known close associates as though they too were PEPs. UK treatment, by contrast, drops the family/associate extension once the PEP exits office. A firm porting UK PEP-exit logic onto a Gibraltar book of business would under-apply continuing obligations precisely where Gibraltar law requires more. The UK-EU Agreement in respect of Gibraltar , signed 14 July 2026 and provisionally applied from the same date, inserts a non-regression commitment at Article 198(2): the UK, in respect of Gibraltar, must not weaken AML/CFT measures below the levels set out in the EU instruments listed at Annex 17, which include Directive 2015/849 as amended, the AML Regulation (2024/1624), the sixth AML Directive (2024/1640), the AMLA Regulation (2024/1620), and the funds-transfer Regulation (2023/1113). Critically, this commitment creates no EU market access or passporting right; it is a floor obligation without a corresponding single-market benefit, and European Parliament consent remains pending with an indicative plenary vote of 14 December 2026. Risk ownership and CDD liability under POCA sections 9B, 10, 13, 15, 20 through 20B, 23 and 26 rests squarely with the Gibraltar legal entity providing the account; reliance on a third party for CDD measures does not discharge that liability, which remains with the relying Gibraltar firm under section 23. Where the entity in question is a Gibraltar branch of a UK company, the risk-owning legal person for UK Money Laundering Regulations purposes shifts to the UK parent under regulation 20, a distinction that matters for groups structuring cross-border compliance functions. #### Cross-Monitor Connections The Funds (Transfer) Regulations 2026 sit at a natural junction between this monitors AML/CTF reading and the digital-asset and payments architecture that World Payments Monitor and crypto-focused trackers follow separately: a single instrument now governs both fiat payment-service-provider transfers and virtual-asset-service-provider transfers under one travel-rule standard, with the same five-year retention and restrictive-measures-policy obligations applying across both rails. The UK-EU Agreements AML non-regression clause likewise connects to enabler-jurisdiction analysis elsewhere in the fleet: Gibraltar now carries an externally-imposed floor referencing the EU AML Package without the offsetting benefit of EU market access, a hybrid posture worth tracking alongside any state-capture or conflict-finance signal that touches UK-aligned offshore centres. #### Outlook The near-term question is less whether Gibraltars standing AML/CTF baseline will move and more whether the UK-EU Agreements non-regression commitment survives European Parliament consent as scheduled for 14 December 2026, and if so, how the Annex 17 reference list is monitored and updated as the underlying EU instruments themselves evolve. The Funds (Transfer) Regulations 2026 travel-rule baseline, now in force, positions Gibraltar ahead of many comparable small jurisdictions on VASP-inclusive information-accompaniment requirements; whether GFSC supervisory practice develops a track record of enforcement against that baseline, or whether the regime remains principally a statement of obligation absent observed enforcement activity, is itself an analytically significant question this monitor will continue to track. 4 Oct 2026 · fim-2026-10-04 Expert reviewed #### Lead Signal Gibraltar has moved its Ultimate Beneficial Ownership Register to free, fully public access, alongside strengthened oversight and increased enforcement activity, a step the Government of Gibraltar itself has framed explicitly as safeguarding the jurisdiction's international reputation in preparation for a forthcoming MONEYVAL assessment. This is a structural transparency upgrade rather than an incident-driven response, and it arrives alongside two supporting legislative amendments: the Register of Ultimate Beneficial Owners, Nominators and Appointors (Amendment) Regulations 2026, made 14 July 2026, and Proceeds of Crime (Amendment) Regulations 2026, made 3 July 2026. The Gibraltar Financial Services Commission intends to carry out supervisory inspections relating to the UBO Regulations across 2026, indicating that the transparency upgrade is being paired with active supervisory follow-through rather than left as a standing rule with no enforcement behind it. #### Other Developments Gibraltar's AML/CTF architecture remains autonomous from the EU framework. Gibraltar's own Parliament legislates its anti-money-laundering regime through the Proceeds of Crime Act 2015, supervised by the Gibraltar Financial Services Commission and assessed by MONEYVAL rather than through the EU AML Package instruments. Gibraltar is not bound by the AML Regulation, the sixth AML Directive, or the AMLA Regulation, reflecting its status outside the EU/EEA post-Brexit. The 2024 FATF follow-up report states that no further reporting is required under MONEYVAL's current round of evaluations, a standing position that has not changed this cycle. #### Cross-Monitor Connections The UBO transparency upgrade sits adjacent to the crypto monitor's coverage of Gibraltar's DLT and Virtual Asset Arrangement framework, where beneficial-ownership visibility questions can also arise for corporate structures engaged in virtual-asset activity; that domain-specific detail is addressed under the crypto monitor rather than analysed further here. The reputational framing around a forthcoming MONEYVAL assessment is also a signal worth tracking for any correspondent-banking or enabler-jurisdiction dynamics that a stronger transparency posture may affect, though no such connection has surfaced as a specific finding this cycle. #### Outlook The scheduling of Gibraltar's next MONEYVAL mutual evaluation round is referenced in the Government of Gibraltar's own communications as the driver behind the recent UBO transparency work, but has not yet been publicly confirmed with a specific date; general industry practice of intensifying beneficial-ownership transparency and enforcement ahead of an evaluation cycle is consistent with what has been observed here. Whether a claimed removal of Gibraltar from an EU high-risk list, currently resting on a single secondary law-firm summary rather than direct confirmation via the EU Official Journal, is corroborated by a primary source is a separate item to watch. The GFSC's stated 2026 supervisory inspection programme relating to the UBO Regulations is the clearest near-term indicator of how seriously the transparency upgrade is being enforced in practice. 5 Sep 2026 · fim-2026-08-21 Expert reviewed #### Lead Signal Gibraltar's ultimate beneficial ownership register has undergone a bifurcation that is likely to draw sustained scrutiny. Following an eighteen-month programme that culminated in free, open access to the register (announced February 2026), two legal notices, LN 147/2026 and LN 220/2026, restored open access for corporate and legal-entity beneficial ownership while carving express trusts out of public inspection entirely. Gibraltar remains one of three UK Overseas Territories with a fully public beneficial-ownership register for corporate entities, but the express-trust carve-out creates a residual channel through which beneficial ownership held via Gibraltar trust structures can now sit outside public view even as corporate transparency is reaffirmed. Read as architecture rather than incident, the pattern is consistent with a jurisdiction calibrating a genuine transparency commitment against a preserved secrecy channel for trust structures, a balance that regulators elsewhere have found difficult to sustain under increasing international scrutiny. This is assessed, not confirmed; sourcing rests on secondary commentary rather than the underlying legal text of LN 147 and LN 220, but the direction of travel, transparency for companies, opacity preserved for trusts, is a structural signal likely to attract scrutiny at Gibraltar's next MONEYVAL mutual evaluation, scheduled for 2027. #### Other Developments Sanctions screening obligations confirmed in force. Gibraltar's Sanctions Act 2019, as amended by the Sanctions (Amendment) Act 2024 (enacted 23 December 2024), requires relevant financial businesses to conduct sanctions screening as part of customer due diligence, maintain supporting policies and controls, and report matches or freeze assets, with non-compliance constituting a criminal offence. This sits atop Gibraltar's existing automatic-recognition mechanism for UN, EU, and UK sanctions regimes. Gibraltar's sanctions architecture continues to rely on automatic recognition of UN, EU, and UK designations under section 6(2)(b) of the Sanctions Act 2019, with no material divergence between those regimes identified this cycle. No designation deltas or enforcement actions were identified this cycle; the finding is the confirmed existence of the screening architecture rather than a new enforcement event. Virtual Asset Arrangements brought within the financial-services perimeter. The Financial Services (Regulated Activities) (Amendment) Regulations 2025 extended the Financial Services Act 2019 to bring Virtual Asset Arrangements, meaning fiat-to-crypto and crypto-to-crypto exchange services, within Part 16 Schedule 2 of the Act from 27 October 2025, requiring explicit permission under Part 7 of the Act alongside legacy DLT Provider status. This is assessed to close a perimeter gap for exchange-type activity, but the finding rests on a single Tier 4 vendor source; it is capped at low confidence pending confirmation from a primary Gibraltar Financial Services Commission publication. UK-EU Gibraltar Treaty carries AML commitments without single-market extension. The 2026 UK-EU Gibraltar Treaty, provisionally applied from 15 July 2026, carries AML/CTF and tax-transparency commitments but does not extend EU financial-services single-market instruments to Gibraltar. Gibraltar's AML/CTF regime therefore continues to operate as an autonomous framework rather than one bound by the EU AML Package. AML/CTF regime of record. Gibraltar's AML/CTF framework rests on the Proceeds of Crime Act 2015, with the Gibraltar Financial Services Commission as supervisor and the Gibraltar Financial Intelligence Unit as the designated financial intelligence unit; the customer due diligence threshold is EUR 15,000, and MONEYVAL is the assessment body. Gibraltar was removed from the FATF grey list in February 2024 and remains off that list, with the next MONEYVAL mutual evaluation scheduled for 2027. As an autonomous jurisdiction, Gibraltar's AML/CTF regime is not derived from any supranational EU legislative competence post-Brexit. #### Cross-Monitor Connections The UBO register bifurcation is directly relevant to any World Payments Monitor assessment of Gibraltar's corporate on-boarding environment, since payment institutions and e-money issuers conducting customer due diligence will need to account for the trust carve-out as a residual opacity channel. The Virtual Asset Arrangements extension similarly intersects with the crypto monitor's licensing coverage of Gibraltar's DLT Provider regime, since the new Part 7 permission requirement sits alongside, rather than replacing, the legacy DLT framework that the crypto monitor tracks directly. Gibraltar's continued autonomy from the EU AML Package, confirmed again this cycle via the UK-EU Gibraltar Treaty's narrow AML-only scope, is a standing structural fact relevant to any advennt assessment of Gibraltar's gambling-sector AML exposure, since gambling operators in Gibraltar sit within the same Proceeds of Crime Act 2015 regime described above rather than any EU-derived instrument. Enablement is itself a signal worth surfacing here: no enforcement action or supervisory sanction tied to the register bifurcation was identified this cycle, and the absence of visible enforcement around a structural transparency rollback of this kind is analytically significant in its own right, not merely a gap in the evidence base. #### Outlook The next material test for Gibraltar's AML/CTF architecture is the MONEYVAL mutual evaluation scheduled for 2027, which will assess the jurisdiction's supervisory effectiveness against the revised FATF Standards. The UBO trust carve-out is likely to be a specific focus of that evaluation given the residual opacity channel it preserves. On the crypto side, primary GFSC confirmation of the Virtual Asset Arrangements permission regime, and the precise legal text of LN 147 and LN 220, are the two gaps most likely to sharpen or revise this cycle's findings once closed. Coverage of D3 (Enabler Jurisdictions) and D4 (Conflict Finance) remained quiet for Gibraltar this cycle; both domains are structurally low-signal for this jurisdiction at present, consistent with Gibraltar's registered-agent-mediated corporate services model rather than indicating any change in exposure. 10 Aug 2026 · fim-2026-08-08 Expert reviewed #### Lead Signal Gibraltar has moved its Ultimate Beneficial Ownership register to free, unhindered public search this cycle, government and supervisory sources confirm, explicitly pairing the change with enhanced oversight and increased enforcement capacity. The government's own announcement commits to providing "free and unhindered access to the UBO Register," and this is corroborated independently by a Gibraltar Financial Services Commission supervisory notice, giving the finding a high-confidence, dual-Tier-1-source basis. For Gibraltar-licensed banks, payment institutions, and cross-sector obliged entities, the GRA's and GFSC's supervisory framework has not itself changed, but the underlying transparency infrastructure their due-diligence teams rely on has become materially easier to corroborate independently. The timing is analytically significant: Gibraltar has been off the FATF grey list since February 2024, and this cycle's UBO enhancement is explicitly framed as preparation for a forthcoming MONEYVAL assessment rather than a reactive response to any adverse finding. Read architecturally rather than as a single event, the move signals proactive effectiveness-focused compliance ahead of assessment, the kind of anticipatory posture that FATF-style mutual evaluations reward, rather than a minimum-compliance reflex adopted only after a critical report. #### Other Developments Autonomous sanctions architecture confirmed. Gibraltar, together with Bermuda, sits outside the Russia (Sanctions)(Overseas Territories) Order 2020 that extended to the UK's other Overseas Territories, and instead operates its own Sanctions Act 2019 regime. The Gibraltar Financial Intelligence Unit confirms, in its own words, that "currently, there are no designations in place" domestically, with UK- and OFSI-notified measures implemented through Gibraltar's own THEMIS system rather than automatic Order-based extension. This is a structural finding corroborated by two independent Tier-1 sources, and it creates a genuine, if narrow, implementation-timing distinction between Gibraltar and Order-bound Overseas Territories — an autonomous but UK-aligned posture rather than a directly derivative one, with a latent evasion-window risk that has not, on current evidence, been exploited. Tokenised fund-share legislation published. The Government of Gibraltar has published the Protected Cell Companies (Amendment) Bill 2026, which would require prior Gibraltar Financial Services Commission approval before any experienced-investor-fund cell can issue tokenised shares. This is an incremental but concrete widening of Gibraltar's distributed-ledger-technology regulatory perimeter into fund infrastructure, layering the existing Proceeds of Crime Act 2015 anti-money-laundering perimeter onto a new tokenisation vector. Independent corroboration of the downstream AML implications specifically remains limited, and the finding is assessed rather than high-confidence pending further primary detail on how GFSC approval conditions will operationalise AML controls for tokenised-share issuance. #### Cross-Monitor Connections The Protected Cell Companies (Amendment) Bill 2026 is a shared reference point across monitors this cycle: it is the same instrument the crypto monitor reads as a new tokenised-fund-share licensing pathway, and the same instrument world-payments reads as a product-innovation development for Gibraltar's funds infrastructure. From a financial-integrity perspective, the relevant lens is the AML perimeter that attaches to any GFSC-approved issuance, since the Bill layers new activity onto the existing Proceeds of Crime Act 2015 supervisory structure rather than creating a parallel compliance regime. Separately, Gibraltar's gambling-sector legislative replacement, tracked in detail by the advennt monitor, is not itself an AML/CTF development, but the new Gambling Operator Support Services licensing category and widened business-to-business scope for overseas suppliers are the kind of structural change in a historically higher-risk sector that a future enabler-jurisdiction or professional-facilitator assessment may need to revisit. #### Outlook The forthcoming MONEYVAL assessment of Gibraltar, expected in 2027 on current general industry expectation, is the organising event for the coming cycles: continued enhancement of UBO-register effectiveness and enforcement pace should be read as preparation against that assessment rather than as isolated developments. On sanctions, the autonomous Sanctions Act 2019 regime combined with zero current domestic designations is a stable structural position, though implementation-timing lag against Order-bound Overseas Territories remains a latent watch item. On the crypto/digital-asset side, the Protected Cell Companies (Amendment) Bill 2026 remains a proposal; its passage and the specificity of the AML conditions GFSC attaches to tokenised-share approval will determine whether this becomes a durable new supervisory vector or a narrow niche product. Domain intelligence (D1–D8) #### Sanctions Gibraltar's sanctions-enforcement architecture gained a new civil penalty track this cycle, sitting alongside the existing criminal offence route under the Sanctions Act 2019. The Sanctions Civil Enforcement Regulations 2026 and the Sanctions Civil Enforcement Authority (Designation) Order 2026, both made 9 September 2026 under the enabling Sanctions (Amendment) Act 2026 of 9 July 2026, give a designated sanctions civil enforcement authority power to impose a monetary penalty where it is satisfied, on the balance of probabilities, that a person has breached a sanctions prohibition. The penalty is recoverable as a civil debt. This is a lower evidentiary bar than the criminal route, which under the existing Sanctions Act 2019 framework can carry up to ten years' imprisonment on indictment but requires proof beyond reasonable doubt. The civil track does not replace the criminal route; it runs alongside it, giving the enforcement authority a choice of mechanism depending on the strength and nature of the evidence available in a given case. Continue reading Gibraltar's underlying sanctions designations continue to be drawn from UK and EU-derived regimes, applied alongside United Nations Security Council measures, a position that has not changed this cycle. What has changed is the enforcement toolkit available once a breach of one of those designations is suspected. For firms with sanctions-screening obligations touching Gibraltar, the practical effect of the new civil track is that enforcement exposure no longer depends solely on securing a criminal conviction; a civil monetary penalty is now available on a materially lower standard of proof. #### Outlook The substantive content of the Sanctions Civil Enforcement Regulations 2026, specifically the penalty quanta and the procedure by which a civil penalty is assessed and imposed, is assessed at Probable confidence pending consolidated GFSC/GFIU civil-penalty tariff guidance under the Sanctions Act 2019. That detail will determine how significant the new civil track proves in practice once the enforcement authority begins using it, and is the primary open item to watch going into the next quarter. #### Beneficial Ownership and Corporate Transparency Gibraltar sits outside the evolving anti-money-laundering supervisory perimeter of the European Union as a matter of structural fact, so the transparency developments most directly relevant to the own regulatory exposure of this jurisdiction are domestic ones. Gibraltar operates its own Register of Ultimate Beneficial Owners, and an assessment by MONEYVAL found that trust and company service providers show a good understanding of beneficial-ownership concepts; the same evaluation found that this is not always the case for other reporting entities, including banks, particularly when complex ownership structures or trusts are involved. This is the primary beneficial-ownership signal for Gibraltar this cycle: a functioning register paired with inconsistent bank-level identification practice once ownership layering or trust structures are introduced, creating a residual opacity vector for illicit proceeds notwithstanding the existence of the register. Continue reading Globally, the EU AML Package sets the structural direction for beneficial-ownership and corporate-transparency supervision across the European Economic Area; in Gibraltar, that package is not the primary subject matter, because as a post-Brexit British Overseas Territory Gibraltar sits entirely outside its supervisory perimeter, with neither the AML Regulation, the sixth AML Directive, nor the AMLA Regulation extending to it directly or indirectly. The only formal linkage of Gibraltar to the EU AML architecture is the high-risk third country delegated-regulation mechanism, from which Gibraltar was delisted via a delegated regulation adopted 10 June 2025, entering legal effect 5 August 2025. As standing structural context for readers assessing beneficial-ownership and corporate-transparency architecture generally, the EU AML Package itself comprises three distinct instruments that recur across the European coverage of this Monitor: the AML Regulation, or AMLR (Regulation (EU) 2024/1624), which applies directly across Member States without national transposition; the sixth AML Directive, or 6AMLD, which each Member State transposes individually into national law; and the AMLA Regulation (Regulation (EU) 2024/1620), which establishes the Anti-Money Laundering Authority itself. The AMLA Regulation creates a direct-and-indirect supervision perimeter under which the Authority takes direct supervisory responsibility for a defined set of higher-risk cross-border obliged entities while continuing to coordinate indirectly with national supervisors for the remainder, shifting the European supervisory model from a purely national architecture toward a hybrid EU-level regime. This is durable structural backdrop against which any EU-side beneficial-ownership development is read; it does not itself apply to Gibraltar, which sits outside the perimeter altogether, and it should be read here as context for the broader European direction of travel rather than as a Gibraltar-specific development. Returning to the own exposure of Gibraltar: the inconsistent bank-level beneficial-ownership identification practice for trusts and complex ownership structures is the more analytically significant gap than the absence of EU-package application, precisely because it sits inside a functioning domestic transparency architecture rather than outside a foreign one. A register that exists but is inconsistently populated or verified at the point of onboarding by non-TCSP reporting entities carries a different risk profile than the absence of any register at all, and it is this distinction, rather than the jurisdictional-perimeter question, that should drive ongoing monitoring of the beneficial-ownership architecture of Gibraltar. #### Outlook The beneficial-ownership architecture of Gibraltar is not currently subject to any dated horizon item forcing near-term change, and its trajectory is assessed as stable. The most likely forcing event remains the next mutual evaluation of Gibraltar, expected in the 2027 to 2029 window, which will test beneficial-ownership identification practice under the more rigorous, effectiveness-focused fifth-round FATF methodology rather than the technical-compliance standard under which the current Register of Ultimate Beneficial Owners was assessed favourably. Whether banks and other non-TCSP reporting entities close the identification gap for trusts and complex structures before that assessment window opens will be the clearest test of whether the transparency architecture of Gibraltar matches its compliance-status profile. #### Enabler Jurisdictions and Professional Facilitators The standing of Gibraltar as an enabler jurisdiction improved on paper this cycle, but the improvement is concentrated in list-status outcomes rather than in the enforcement-capacity gaps that determine whether professional-facilitator risk is actually contained. Gibraltar was removed from the FATF Jurisdictions under Increased Monitoring list on 23 February 2024, alongside Barbados, Uganda and the United Arab Emirates, and was subsequently delisted from the European Union anti-money-laundering high-risk third country list via a delegated regulation adopted by the European Commission on 10 June 2025, entering legal effect 5 August 2025. Both delistings close a multi-year technical-compliance remediation track and represent the clearest positive signal in this baseline. Continue reading Set against that improving list-status trajectory, two structural gaps persist that are independent of technical-compliance ratings. Organised criminal groups operating on the Gibraltar-Spain frontier generate high cash volumes through duty-differential tobacco smuggling, an active scheme layering cash proceeds through cash-intensive local businesses on both sides of the border; this is a persistent, MONEYVAL-documented channel rather than a new development, and its continuation alongside an improving compliance-status profile is itself an architecture-over-incident finding, since a clean technical-compliance rating does not, on its own, close an active cross-border cash-laundering channel. Separately, Gibraltar authorities make a low number of outgoing mutual legal assistance requests relative to the cross-border, complex nature of proceeds of crime affecting the jurisdiction, a capacity gap that limits the ability to trace and confiscate proceeds of foreign predicate offences layered through the local financial and corporate services sector, including proceeds that may pass through the tobacco-smuggling channel itself. Professional and financial-services access of Gibraltar to the UK market also continues to run on a transitional rather than settled basis. The UK-Gibraltar transitional financial-services market access arrangement has been extended a further twelve months, to 16 December 2026, pending finalisation of the Gibraltar Authorisation Regime. The recurring annual extension without full finalisation of that Regime leaves open a structural question about the durability of the alignment-based supervisory cooperation model underpinning the market access of Gibraltar to the UK, a question that sits alongside, rather than is resolved by, the improving FATF and EU list-status of Gibraltar. Read together, these three findings describe an enabler-jurisdiction profile in which the compliance-status headline and the enforcement-capacity substrate are moving, or at least persisting, on largely independent tracks. The delistings address the technical-compliance dimension that FATF and EU list-status mechanisms are designed to measure; they do not, on the evidence available this cycle, address the frontier cash-laundering channel, the MLA capacity gap, or the durability of the UK market-access relationship. #### Outlook The next mutual evaluation of Gibraltar, expected in the 2027 to 2029 window, will apply the tougher, effectiveness-focused fifth-round FATF methodology, which is likely to test precisely the gap this cycle identifies between improving list-status and persistent enforcement-capacity limitations, including outgoing MLA volume and the tobacco-smuggling channel. Separately, the 16 December 2026 expiry of the transitional UK-Gibraltar market access arrangement is the more immediate dated forcing event: whether it is superseded by a finalised Gibraltar Authorisation Regime, or extended again on the existing annual basis, will be the clearest near-term signal of whether the alignment-based cooperation model is converging toward a settled long-term footing. #### Conflict Finance and Extractive-Industry Integrity No Gibraltar-specific conflict-finance or extractive-industry integrity material was identified in this baseline cycle. The jurisdiction-risk profile of Gibraltar this cycle is built from sanctions-architecture, beneficial-ownership, enabler-jurisdiction, digital-asset and compliance-technology findings; none of the evidence gathered for this baseline surfaced a Gibraltar-linked financial flow sustaining armed conflict or an extractive-industry corruption channel routed through the jurisdiction. The standing global D4 coverage of this Monitor, tracking Russian war-economy financing, Sahel minerals and Democratic Republic of Congo governance, is carried forward unchanged and is not itself part of this Gibraltar-specific baseline. Continue reading Honesty over coverage governs this entry: rather than construct a Gibraltar-specific conflict-finance narrative from adjacent findings, principally the Maritime Mutual Gibraltar Russia-sanctions wind-down, which belongs analytically to the sanctions-architecture domain rather than to conflict finance as this Monitor defines it, this baseline records the absence directly. That absence is itself a useful baseline marker: any future cycle in which Gibraltar-linked conflict-finance material does emerge should be read against this recorded absence as a genuinely new signal rather than continuation of an existing pattern. #### Outlook No dated horizon item currently ties Gibraltar to this domain. The domain will remain on standing-coverage status for this jurisdiction until Gibraltar-specific evidence emerges; the most plausible future connective tissue, based on the findings of this cycle elsewhere in the baseline, would run through the marine-insurance and shipping sector already surfaced under sanctions architecture, should any conflict-finance-relevant cargo or vessel-ownership pattern be identified in that sector in a future cycle. #### Crypto / Digital Assets / Financial Innovation Revolut Global Digital Assets Limited, a newly established Gibraltar entity, obtained a Gibraltar Financial Services Commission DLT Provider licence for virtual-asset order execution, custody and staking, announced 19 October 2026. The grant expands the population of GFSC-supervised virtual asset service providers that sit within Gibraltar's Proceeds of Crime Act 2015 travel-rule and anti-money-laundering perimeter. Because the new entity is licensed directly by the GFSC rather than operating through an unregulated channel, its virtual-asset activity becomes subject to the same supervisory and reporting structure that already applies to other GFSC-licensed DLT providers in Gibraltar. Continue reading The addition is notable less for its individual scale than for what it signals about the trajectory of GFSC-supervised digital-asset activity in Gibraltar: a well-known payments and e-money group establishing a dedicated Gibraltar vehicle specifically to hold a virtual-asset custody and execution permission indicates continued use of Gibraltar's licensing regime as a base for combined digital-asset and payments propositions. For the purposes of the jurisdiction's AML/CFT exposure, each new GFSC-licensed virtual asset service provider represents an incremental addition to the population subject to travel-rule obligations under the Proceeds of Crime Act 2015, rather than a change to the underlying rule itself. #### Outlook Whether additional digital-asset entities follow a similar path of establishing dedicated Gibraltar vehicles for virtual-asset permissions is the principal item to watch. The substance of ongoing supervisory engagement between the GFSC and its licensed virtual-asset population, including how travel-rule compliance is tested in practice, was not confirmed this cycle and remains an open area for future observation. #### Compliance Technology and Active Defence The approach of Gibraltar to digital-asset supervision doubles as the clearest illustration this cycle of the proactive-versus-tick-box compliance debate within the D6 domain of this Monitor. The Gibraltar Financial Services Commission applies ten outcomes-focused principles to distributed ledger technology and virtual-asset-service-provider activity rather than prescriptive rules, a supervisory design that in principle should allow the regulator to respond dynamically to novel typologies without waiting for legislative amendment. Whether that design translates into consistent case-level supervisory outcomes, however, is difficult to verify externally. Continue reading That verification difficulty is itself the second finding of the domain this cycle. The Gibraltar Financial Services Commission does not maintain a highly visible public enforcement-notices archive relative to comparator regulators, and open-source coverage of firm-level enforcement outcomes over the prior eighteen months is thin. This is recorded here as a gap in available open-source intelligence coverage of GFSC enforcement outputs specifically, rather than as any finding about the internal control environment of any regulated firm; no corroborating source was identified confirming either the presence or absence of underlying enforcement activity, only the absence of its public surfacing. The combination of these two findings is what makes this a D6, active-defence-relevant observation rather than a simple transparency complaint. A principles-based, outcomes-focused supervisory model depends more heavily than a prescriptive rules-based one on visible enforcement outcomes to demonstrate that the principles are being applied with real consequence; in the absence of a visible enforcement record, external assessors, including this Monitor, cannot distinguish between a genuinely light-touch-but-effective regime and one that is light-touch because enforcement is not occurring. This is a structural gap in the assessment architecture itself, not a statement about the underlying supervisory performance of Gibraltar. This verification gap sits alongside the principles-based digital-asset licensing regime of Gibraltar, discussed in the D5 coverage of this Monitor, which similarly relies on outcomes-focused judgement calls rather than prescriptive checklists. The same feature that makes the compliance-technology posture of Gibraltar forward-leaning in principle, discretion exercised by the regulator rather than compliance with fixed rules, is also what makes real-world application hardest to verify from outside the institution, whether the object of assessment is DLT/VASP licensing or broader firm-level enforcement. Read across the three pillars this Monitor tracks, the D6 profile of Gibraltar this cycle is anti-money-laundering-weighted by default, because the enforcement-transparency gap and the principles-based licensing model are both AML/CFT-facing observations; no CTF- or CPF-specific compliance-technology signal was identified for Gibraltar this cycle, an absence that is itself worth noting given the separately assessed low private-sector awareness of proliferation-financing obligations documented elsewhere in this baseline. #### Outlook Absent a comparator-style public enforcement-notices archive, comparable to peer regulators such as the Guernsey Financial Services Commission, external verification of the principles-based supervisory model of Gibraltar will remain constrained between MONEYVAL assessment cycles. The trajectory of the domain is assessed as one to watch rather than one showing a clear direction, precisely because the underlying supervisory model may be functioning well without that functioning being externally visible. The next dated test will be the fifth-round mutual evaluation of Gibraltar, expected 2027 to 2029, which will assess supervisory effectiveness directly rather than relying on public enforcement-notice visibility as a proxy. #### AML/CTF Regime Gibraltar's anti-money-laundering and counter-terrorist-financing regime, as it currently stands, is anchored in the Proceeds of Crime Act 2015, which establishes the Gibraltar Financial Intelligence Unit and sets out, in Part III, the customer due diligence, record-keeping and suspicious-activity-reporting duties applicable to relevant financial businesses. A relevant financial business must apply customer due diligence measures before establishing a business relationship or occasional transaction, applying an occasional-transaction threshold of 15,000 euros for non-financial-sector relevant persons. Where the money-laundering reporting officer determines that grounds for knowledge or suspicion of money laundering, terrorist financing or proliferation financing are satisfied, the matter must be reported to the Financial Intelligence Unit without delay; where the Unit refuses consent to a prospective transaction, a sixty-working-day moratorium period applies before the firm may proceed. Disclosing that a suspicious-activity report has been made, or that an investigation is contemplated or under way, where that disclosure is likely to prejudice the investigation, is a separate criminal offence, subject to statutory exceptions including disclosure to the Financial Intelligence Unit, police or customs. Money-laundering offences under the Act carry criminal penalties of up to fourteen years imprisonment and unlimited fines. Documents and information obtained through customer due diligence, together with records of due diligence measures and ongoing monitoring, must be retained for five years from the date an occasional transaction is completed or a business relationship ends. Continue reading Supervisory enforcement of this regime sits with the Gibraltar Financial Services Commission, which under the Supervisory Bodies (Powers etc.) Regulations 2017 may impose an administrative penalty on a relevant person for default or breach of Proceeds of Crime Act obligations up to the higher of twice the benefit derived or 1 million euros for most relevant persons, rising to 5 million euros or 10 percent of total annual turnover for credit and financial institutions. A possible successor instrument dated 2025, carrying a comparable 1 million euro cap, has been identified as a research lead but has not been independently confirmed as superseding the 2017 framework, and should be treated as unconfirmed pending further verification. Against this penalty architecture, the Commission concluded four firm-level settlements in the 2023 to 2025 period: Tap Global Limited paid 150,000 pounds for failing to follow internal suspicious-activity-reporting procedures between April 2023 and June 2024; Blacktower Financial Management (International) Limited paid 294,479 pounds following two 2023 onsite reviews that found customer due diligence, sanctions-screening, monitoring and training failures; and Alvar Financial Services Limited and Argon Financial Limited paid 186,038.52 pounds and 71,281 pounds respectively for failing to demonstrate effective control and management between April 2021 and May 2024. Separately, sanctions obligations sit alongside the core anti-money-laundering framework under the Sanctions Act 2019, which provides automatic recognition in Gibraltar of United Nations, United Kingdom and European Union sanctions together with autonomous domestic designations, and the Sanctions (Amendment) Act 2024, which recast the screening-related provisions previously found at section 8(3) and (4) of the 2019 Act. An Unexplained Wealth Order regime, introduced by amendments to the Proceeds of Crime Act that took effect in October 2024, allows the Supreme Court to require a respondent, typically a politically exposed person or person suspected of serious crime, to explain how property worth more than 50,000 pounds was acquired where known lawful income appears insufficient; making a false statement in response to such an order is an offence carrying up to two years imprisonment. On the international-assessment dimension, Gibraltar's 2024 second enhanced follow-up report re-rated Financial Action Task Force Recommendation 36 to Largely Compliant, bringing all forty Recommendations to a rating of either Compliant or Largely Compliant and terminating the enhanced follow-up procedure that the regional mutual-evaluation body, the Committee of Experts on the Evaluation of Anti-Money Laundering Measures, had previously maintained with Gibraltar following its 2019 mutual evaluation report. Gibraltar's 2025 National Risk Assessment, the first full update since 2020, identifies company management, cross-border finance, virtual assets and cyber-enabled fraud as priority high-risk areas, and flags Spain and Morocco as higher-risk neighbouring jurisdictions. #### Outlook Gibraltar's sixth-round mutual evaluation is provisionally scheduled, with an on-site visit indicated for October 2027 and a Plenary discussion around May 2028; these dates are provisional per the regional evaluation body's own published schedule and should not be treated as fixed. A consultation on enhanced customer due diligence obligations aligned with an updated Financial Action Task Force Recommendation 16, targeting virtual-asset-service providers and correspondent banking, has been signalled by the Gibraltar Financial Services Commission but rests on a single source with no confirmed date, and its scope and timetable remain unresolved. The question of whether a 2025 instrument has in fact superseded the 2017 supervisory penalty framework is likewise unresolved and warrants confirmation before being treated as the current position. #### Commercial Activity As at November 2026, the operational throughput of Gibraltar's financial-intelligence reporting architecture provides the current standing picture of commercial-sector engagement with the anti-money-laundering regime. The Gibraltar Financial Intelligence Unit received more than 5,800 suspicious-activity reports over the course of 2025, an increase of 17.5 percent on the prior year's total of 4,950, which the Unit itself characterised as a landmark year for reporting volume. Within that increase, the virtual-asset-service-provider sector's own disclosures nearly doubled, indicating that crypto-asset businesses operating under Gibraltar's distributed-ledger-technology and virtual-asset-service-provider frameworks are a growing contributor to the jurisdiction's overall suspicious-activity-reporting flow, alongside banking, payments, investment and gambling-sector reporting entities. Continue reading Alongside the reporting-volume data, the Financial Intelligence Unit's statistics for the second quarter of 2025 show the operation of the consent mechanism that sits beneath the suspicious-activity-reporting regime: 194 requests for consent to proceed with a transaction despite a suspicion of money laundering were received in that quarter, of which 166, representing 86 percent, were granted. This grant rate describes the practical day-to-day interaction between regulated firms and the Financial Intelligence Unit where a reporting entity has identified a transaction that may be connected to money laundering, terrorist financing or proliferation financing but wishes to continue dealing with the underlying funds or relationship. The consent and moratorium mechanism which governs this process, found in the Proceeds of Crime Act 2015, provides that where consent is refused a sixty-working-day moratorium period applies before a firm may proceed, a structural feature that frames the context in which the 86 percent grant rate for the second quarter of 2025 should be read. Taken together, these figures describe a financial-intelligence apparatus processing a reporting volume that has grown meaningfully year on year, across a commercial base that spans traditional banking, payments, investment, gambling and virtual-asset activity, with a consent-request grant rate that suggests the large majority of requests to proceed despite a flagged suspicion are being resolved in favour of the reporting entity within the quarter examined. No equivalent commercial-activity statistics beyond these two data points, drawn from the suspicious-activity-reporting and deferred-action consent channels, have been identified for the current reporting position. #### Outlook Whether the 17.5 percent year-on-year rise in suspicious-activity-report volume recorded for 2025 represents a sustained upward trajectory or a single landmark year, as the Financial Intelligence Unit itself described it, is not yet established from the data available, and subsequent quarterly and annual statistical releases will be needed to determine whether reporting volume continues to climb, particularly within the virtual-asset-service-provider sector where disclosures nearly doubled. Continued growth in reporting volume, if it occurs, would be expected to place additional demands on the Financial Intelligence Unit's consent-processing capacity, a dimension on which only a single quarter of data, that for the second quarter of 2025, is currently available. Regulatory horizon No dated horizon items this cycle. 1 item tracked without a confirmed date. 1 pending date · baseline fim-2026-07-05 Role action cards MLRO ### The Gibraltar Financial Intelligence Unit recorded a 17.5 percent year-on-year rise in suspicious-activity reports for 2025, with virtual-asset-sector disclosures nearly doubling. Reporting officers overseeing Gibraltar-regulated entities, particularly those in the virtual-asset-service-provider sector, operate within a reporting environment where overall volume and crypto-sector share are both rising; the consent and sixty-working-day moratorium mechanism under the Proceeds of Crime Act 2015 remains the operative framework for transactions subject to a pending suspicion. 3 evidence refs Compliance ### Four Gibraltar Financial Services Commission settlements concluded between 2023 and 2025 found customer due diligence, sanctions-screening, suspicious-activity-reporting and control failures across crypto, investment and payments firms. The settlements with Tap Global, Blacktower, Alvar and Argon collectively demonstrate active supervisory testing of core control-framework elements, including internal reporting procedures, sanctions screening and effective management, with penalties reaching into the hundreds of thousands of pounds. 4 evidence refs Legal ### An Unexplained Wealth Order regime, in effect since October 2024, allows the Supreme Court to require explanation of property exceeding 50,000 pounds where lawful income appears insufficient. Counsel advising on Gibraltar wealth-structuring or politically-exposed-person matters should treat the Unexplained Wealth Order mechanism, and the associated false-statement offence carrying up to two years imprisonment, as a live enforcement tool under the amended Proceeds of Crime Act 2015. 1 evidence refs Board ### Gibraltar achieved Largely Compliant or Compliant ratings on all forty FATF Recommendations in 2024, ending enhanced monitoring by the regional mutual-evaluation body, while supervisory enforcement activity continued through 2025. The combination of a positive international compliance rating and continued active enforcement signals a jurisdiction maintaining reputational standing through visible supervisory action rather than through an absence of findings; a sixth-round mutual evaluation is provisionally scheduled for 2027 to 2028. 4 evidence refs CTO ### Virtual-asset-service-provider suspicious-activity-report disclosures nearly doubled in 2025, within a regime requiring Part 7 authorisation for distributed-ledger-technology providers and Travel Rule compliance at a 1,000 euro threshold. Technology functions supporting Gibraltar-licensed crypto-asset operations should note the authorisation requirement under the 2020 Distributed Ledger Technology Providers Regulations and the originator/beneficiary information-transmission duty under the Travel Rule, against a backdrop of rising sector-specific reporting volume and at least one enforcement settlement, Tap Global, concerning internal reporting-procedure failures. 2 evidence refs Risk ### Gibraltar's 2025 National Risk Assessment identifies company management, cross-border finance, virtual assets and cyber-enabled fraud as priority high-risk areas, with Spain and Morocco flagged as higher-risk neighbouring jurisdictions. Risk functions should weigh the National Risk Assessment's priority areas alongside the observed concentration of enforcement actions in investment-management and crypto-payments firms, and the rising suspicious-activity-report trajectory, when calibrating exposure assessments tied to Gibraltar-domiciled counterparties. 1 evidence refs Operations ### Second-quarter 2025 data shows 194 consent requests received and 166, or 86 percent, granted under the deferred-action mechanism. Operational teams handling transaction screening and consent requests tied to Gibraltar reporting entities can reference this single-quarter grant-rate figure as a baseline for current throughput, noting that only one quarter of data is available and the moratorium period of sixty working days applies where consent is refused. 2 evidence refs Audit ### Documents and information obtained through customer due diligence must be retained for five years from the end of a business relationship or completion of an occasional transaction, under the Proceeds of Crime Act 2015. Audit functions testing control adequacy for Gibraltar-regulated entities should confirm that the five-year record-retention requirement is being met, and may wish to cross-reference the control and management deficiencies identified in the Alvar and Argon settlements as a benchmark for documentation-gap risk. 2 evidence refs Scenario sketches ### Supervisory capacity under rising suspicious-activity-report volume An illustrative orientation only: if suspicious-activity-report volume in a small jurisdiction continues to climb at a rate comparable to the 17.5 percent year-on-year increase observed for 2025, with virtual-asset-sector disclosures growing fastest, a financial intelligence unit of fixed size could face a widening gap between report intake and triage capacity. This could plausibly manifest as lengthening time-to-decision on consent requests, or a shift toward higher automatic-grant rates as a release valve, neither of which is observed in the data examined and both of which remain speculative illustrations of a structural pressure, not a prediction of Gibraltar's actual trajectory. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Sanctions Regime stable T2 · Beneficial Ownership Transparency stable T3 · Enabler Jurisdiction Risk stable T4 · Conflict Finance Exposure no_change T5 · Sanctions Regime Divergence no_change T6 · Compliance Technology and Active Defence no_change Registers ### Enforcement actions - 6 Oct 2025 - 20 Feb 2025 - 20 Feb 2025 - 20 Feb 2025 ### List status & mutual evaluation - 23 Feb 2024 - 22 May 2024 - 10 Jun 2025 ### Sanctions changes - 24 Feb 2026 - 23 Apr 2026 - 1 Jun 2026 - 16 Jun 2026 - 24 Feb 2026 - OFSI General Licence INT/2026/8893924 authorised wind-down of Maritime Mutual Gibraltar insurance policies affected by Russia sanctions designations, permitting an orderly unwind rather than abrupt policy termination. 24 Feb 2026 - European Commission delegated regulation removed Gibraltar from the EU list of AML/CFT high-risk third countries requiring mandatory enhanced due diligence by EU obliged entities. 10 Jun 2025 - Structural point confirmed via UK secondary legislation: all British Overseas Territories except Bermuda and Gibraltar have UK Russia sanctions extended to them via the Russia (Sanctions) (Overseas Territories) Order 2020; Gibraltar and Bermuda instead implement sanctions under their own domestic legislative arrangements (Gibraltar's Sanctions Act 2019), meaning designation timing, licensing and enforcement in Gibraltar run on a jurisdiction-specific track rather than automatic extension of UK statutory instruments. 17 Apr 2024 ### Regulatory horizon (register) - European Parliament consent on UK-EU Gibraltar Agreement - Sanctions Civil Enforcement Regulations 2026 substantive provisions to be tested - MONEYVAL 6th-round mutual evaluation of Gibraltar - GFSC CDD consultation aligned with FATF R.16 - MONEYVAL sixth-round mutual evaluation of Gibraltar - Possible supersession of Supervisory Bodies (Powers etc.) Regulations 2017 enforcement framework - ### Active schemes - Gibraltar-domiciled marine insurance wind-down for Russia-exposed vessels - Cross-frontier tobacco smuggling and cash-intensive laundering - Gibraltar DLT/virtual-asset licensing as light-touch crypto hub - Trust and complex-ownership structuring via Gibraltar TCSPs Sources - [UK Financial Sanctions FAQs - GOV.UK](https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs) - [HM Government of Gibraltar](https://www.gibraltar.gov.gi/press-releases/government-of-gibraltar-announces-landmark-legislation-enabling-tokenised-fund-shares-3012026-11929) - [Gibraltar Financial Services Commission](https://www.fsc.gi/aml) - [Council of Europe / MONEYVAL](https://www.coe.int/en/web/moneyval/-/moneyval-welcomes-gibraltar-s-removal-from-the-from-fatf-s-grey-list-1) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Gibraltar.html) - [Gibraltar Financial Intelligence Unit](https://www.gfiu.gov.gi/sanctions) - [House of Commons Library](https://commonslibrary.parliament.uk/research-briefings/cbp-9485/) - [company.gi](https://company.gi/blog/gibraltar-ubo-register) - [GOV.UK](https://www.gov.uk/government/collections/uk-eu-agreement-in-respect-of-gibraltar) - [https://www.fatf-gafi.org/en/countries/detail/Gibraltar.html](https://www.fatf-gafi.org/en/countries/detail/Gibraltar.html) - [https://www.coe.int/en/web/moneyval/-/moneyval-welcomes-gibraltar-s-removal-from-the-from-fatf-s-grey-list-1](https://www.coe.int/en/web/moneyval/-/moneyval-welcomes-gibraltar-s-removal-from-the-from-fatf-s-grey-list-1) - [https://www.gibraltar.gov.gi/press-releases/ultimate-beneficial-ownership-register-1112026-11724](https://www.gibraltar.gov.gi/press-releases/ultimate-beneficial-ownership-register-1112026-11724) - [https://signaturelitigation.com/elliott-phillips-and-chris-edwards-discuss-gibraltars-new-ubo-register-in-thomson-reuters-regulatory-intelligence/](https://signaturelitigation.com/elliott-phillips-and-chris-edwards-discuss-gibraltars-new-ubo-register-in-thomson-reuters-regulatory-intelligence/) - [https://www.gibraltarlaw.com/media/2026/03/Country-Update-Gibraltar-AML-2026.pdf](https://www.gibraltarlaw.com/media/2026/03/Country-Update-Gibraltar-AML-2026.pdf) - [https://www.gibraltar.gov.gi/sanctions](https://www.gibraltar.gov.gi/sanctions) - [https://www.fsc.gi/aml](https://www.fsc.gi/aml) - [https://ramparts.gi/the-gibraltar-authorisation-regime-gar-uk-market-access/](https://ramparts.gi/the-gibraltar-authorisation-regime-gar-uk-market-access/) - [https://committees.parliament.uk/writtenevidence/92/html/](https://committees.parliament.uk/writtenevidence/92/html/) - [https://bit2me.com/cryptocurrencies/gibraltar](https://bit2me.com/cryptocurrencies/gibraltar) - [https://www.coe.int/en/web/moneyval](https://www.coe.int/en/web/moneyval) - [https://www.coe.int/en/web/moneyval/assessment-calendar](https://www.coe.int/en/web/moneyval/assessment-calendar) - [https://www.gbc.gi/news/govt-holds-constructive-talks-with-council-of-europe-moneyval-team-ahead-of-gibraltar-evaluation](https://www.gbc.gi/news/govt-holds-constructive-talks-with-council-of-europe-moneyval-team-ahead-of-gibraltar-evaluation) - [https://www.gibraltarlaws.gov.gi/legislations/funds-transfer-regulations-2026-8478/download](https://www.gibraltarlaws.gov.gi/legislations/funds-transfer-regulations-2026-8478/download) - [https://company.gi/guide/prediction-markets/financial-crime](https://company.gi/guide/prediction-markets/financial-crime) - [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202501184](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202501184) - [https://www.gibraltarlaws.gov.gi/uploads/legislations/financial-services/2019-26/2025=254.pdf](https://www.gibraltarlaws.gov.gi/uploads/legislations/financial-services/2019-26/2025=254.pdf) - [https://www.gibraltarlaws.gov.gi/legislations/proceeds-of-crime-act-2015-2348/download](https://www.gibraltarlaws.gov.gi/legislations/proceeds-of-crime-act-2015-2348/download) - [https://www.gibraltar.gov.gi/uploads/Financial-Crime/2025NRA%20v1.3.pdf](https://www.gibraltar.gov.gi/uploads/Financial-Crime/2025NRA%20v1.3.pdf) - [https://www.fsc.gi/uploads/aml/4%20-%20Customer%20Risk%20Assessment.pdf](https://www.fsc.gi/uploads/aml/4%20-%20Customer%20Risk%20Assessment.pdf) - [https://assets.publishing.service.gov.uk/media/6a56149a6d6d5c7e2845c8d1/MS_9.2026_Agreement_Gibraltar_UK_EU_EAEC_v1of2.pdf](https://assets.publishing.service.gov.uk/media/6a56149a6d6d5c7e2845c8d1/MS_9.2026_Agreement_Gibraltar_UK_EU_EAEC_v1of2.pdf) - [Council of Europe / MONEYVAL](https://www.coe.int/en/web/moneyval/-/moneyval-report-on-gibraltar-sees-improvement-in-fighting-money-laundering-and-terrorist-financing) - [Council of Europe / MONEYVAL](https://www.coe.int/en/web/moneyval/assessment-calendar) - [Government of Gibraltar](https://www.gibraltarlaws.gov.gi/legislations/sanctions-act-2019-4573/download) - [Government of Gibraltar](https://gibraltarlaws.gov.gi/legislations?topic=416) - [Government of Gibraltar](https://www.gibraltarlaws.gov.gi/uploads/legislations/proceeds-of-crime/2021s194/2021s194.pdf) - [Gibraltarlaw.com (law firm)](https://www.gibraltarlaw.com/media/2026/03/Country-Update-Gibraltar-AML-2026.pdf) - [Bullish Group (company announcement)](https://www.bullish.com/us/news-insights/bullish-receives-gibraltar-financial-services-commission-approval-to-offer-trading-in-tokenized-securities) - [Tracxn](https://tracxn.com/d/explore/fintech-startups-in-gibraltar/__38FtfxfYPbd2pJZUtqxChz7Y1R-79-xTVxOobNPHITE) - [https://rm.coe.int/moneyval-2024-5-gib-5thround-2ndenhfur/1680b06419](https://rm.coe.int/moneyval-2024-5-gib-5thround-2ndenhfur/1680b06419) - [https://www.chronicle.gi/moneyval-experts-say-gibraltar-has-improved-measures-for-tackling-money-laundering-and-terrorist-financing/](https://www.chronicle.gi/moneyval-experts-say-gibraltar-has-improved-measures-for-tackling-money-laundering-and-terrorist-financing/) - [https://www.gibraltarlaws.gov.gi/legislations/sanctions-act-2019-4573/download](https://www.gibraltarlaws.gov.gi/legislations/sanctions-act-2019-4573/download) - [https://gibraltarlaws.gov.gi/legislations?topic=416](https://gibraltarlaws.gov.gi/legislations?topic=416) - [https://www.theblock.co/news/regulation/2026-10-19-revolut-secures-gibraltar-crypto-licence-to-support-international-expansion-plans-418889](https://www.theblock.co/news/regulation/2026-10-19-revolut-secures-gibraltar-crypto-licence-to-support-international-expansion-plans-418889) - [Gibraltar Financial Intelligence Unit](https://www.gfiu.gov.gi/sanctions) - [Gibraltar Financial Intelligence Unit](https://www.gfiu.gov.gi/uploads/docs/publications/Financial%20Sanctions%20Guidance%20Notes%20v1.2.pdf) - [Government of Gibraltar](https://www.gibraltar.gov.gi/finance-gaming-and-regulations/sanctions) - [National Coordinator for AML/CFT, HM Government of Gibraltar](https://www.gibraltar.gov.gi/uploads/Gambling/Press%20Releases/NCO%20Newsletter%20of%20Legislative%20Changes%20February%202021.pdf) - [Gibraltarlaw.com / Thomson Reuters](https://www.gibraltarlaw.com/media/2026/03/Country-Update-Gibraltar-AML-2026.pdf) - [Gibraltar Finance / Government of Gibraltar](https://www.gibraltarfinance.gi/uploads/UBO/Technical%20GN%20-%20Changes%20%20FAQ%20(CA)%20-%20Updated%2005.02.26_%20(002).pdf) - [Resilience Group](https://www.resilience.gi/faq/companies/) - [Gibraltar Financial Services Commission](https://www.fsc.gi/uploads/AML%20Guidance%20Notes/5%20-%20Customer%20Due%20Diligence.pdf) - [Gibraltar Financial Services Commission](https://www.fsc.gi/uploads/AML%20Guidance%20Notes/7%20-%20Politically%20Exposed%20Persons.pdf) - [Government of Gibraltar (gibraltarlaws.gov.gi)](https://www.gibraltarlaws.gov.gi/legislations/proceeds-of-crime-act-2015-2348/version/22-12-2016/download) - [HM Government of Gibraltar, National Coordinator for AML/CFT](https://www.gibraltar.gov.gi/uploads/Gambling/Documents/Further%20Guidance%20-%20AML%20Issues%20-%202022.pdf) - [Office of Fair Trading, HM Government of Gibraltar](https://oft.gov.gi/aml-cft) - [Government of Gibraltar](https://www.gibraltarlaws.gov.gi/uploads/legislations/financial-services/2019-26/2019-26(16-12-21).pdf) - [Gibraltar Financial Services Commission](https://www.fsc.gi/uploads/LRP/Financial%20Services%20(Distributed%20Ledger%20Technology%20Providers)%20Regulations%202020.pdf) - [Notabene](https://notabene.id/world/gibraltar) - [Government of Gibraltar](https://www.gibraltarlaws.gov.gi/legislations/proceeds-of-crime-act-2015-2348/download) - [Parliament of Gibraltar](https://www.parliament.gi/uploads/contents/bills/2024/2024B25.pdf) - [Gibraltar Financial Services Commission](https://fsc.gi/news/regulatory-settlement-agreement-between-the-gibraltar-financial-services-commission-and-tap-global-limited-558?print=) - [GBC News](https://www.gbc.gi/news/fsc-fines-gibraltar-registered-company-nearly-300000-violating-proceeds-crime-act-regulations) - [GBC News](https://www.gbc.gi/news/investment-companies-fined-over-250000-falling-below-regulatory-standard) - [FATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Gibraltar-FUR-2024.html) - [National Coordinator for AML/CFT, HM Government of Gibraltar](https://www.gibraltar.gov.gi/uploads/Gambling/Documents/2025NRA%20-%20FINAL.pdf) - [Gibraltar Chronicle](https://www.chronicle.gi/gibraltar-cannot-stand-still-on-compliance-efforts/) - [World Offshore Banks](https://www.worldoffshorebanks.com/gibraltar-offshore-banking-intelligence-center.php) - [Signature Litigation](https://signaturelitigation.com/elliott-phillips-and-chris-edwards-discuss-gibraltars-new-ubo-register-in-thomson-reuters-regulatory-intelligence/) - [FATF / MONEYVAL](https://www.fatf-gafi.org/en/countries/global-network/committee-of-experts-on-the-evaluation-of-anti-money-laundering-.html) - [Gibraltar Financial Services Commission](https://www.fsc.gi/uploads/AML%20Guidance%20Notes/11%20-%20Suspicious%20Activity%20Reporting.pdf) - [Government of Gibraltar (gibraltarlaws.gov.gi)](https://www.gibraltarlaws.gov.gi/legislations/proceeds-of-crime-act-2015-2348/version/10-03-2022/download) - [Gibraltar Gambling Commissioner](https://www.gibraltar.gov.gi/uploads/Gambling/Documents/Published%20-%20AML%20Code%20-%20Remote%20-%20POCA%20Update%202021.pdf) - [Government of Gibraltar (gibraltarlaws.gov.gi)](https://www.gibraltarlaws.gov.gi/legislations/supervisory-bodies-powers-etc-regulations-2017-4134/version/13-06-2019/download) - [GBC News](https://www.gbc.gi/news/gfiu-sees-175-rise-in-suspicious-activity-reports-in-landmark-year) - [Gibraltar Financial Intelligence Unit (GFIU)](https://gfiu.gov.gi/uploads/docs/Statistics%20Reports/Q2%202025%20Statistics%20Report.pdf) - [Government of Gibraltar (gibraltarlaws.gov.gi)](https://www.gibraltarlaws.gov.gi/uploads/legislations/sanctions/2025s060/2025s060.pdf) - [Gibraltar Regulatory Authority](https://www.gra.gi/uploads/documents/data-protection/E-Newsletters/2026/Q1%202026%20-%20Final.pdf) - [British Overseas Territory of Gibraltar](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Moneyval-Mutual-Evaluation-Report-Gibraltar.pdf.coredownload.inline.pdf) - [Gibraltar](https://www.fatf-gafi.org/en/countries/detail/Gibraltar.html) - [Fatf-gafi](https://www.fatf-gafi.org/media/fatf/documents/reports/mer-fsrb/Moneyval-Mutual-Evaluation-Report-Gibraltar.pdf) - [Gibraltar's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Gibraltar-FUR-2024.html) - [Gibraltar's measures to combat money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mer-gibraltar-2019.html) - [1 Anti-money laundering and counter-terrorist financing measures Gibraltar](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/MONEYVAL-FUR-Gibraltar-Dec-2021.pdf.coredownload.inline.pdf) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [Gibraltar Assessment](https://www.fincen.gov/system/files/shared/Gibraltar_%20Assessment.pdf) - [Money laundering and terrorist financing risks](https://www.fatf-gafi.org/en/publications/Methodsandtrends/Ml-tf-risks.html) - [FATF launches National Risk Assessment toolkit to help countries identify greatest money laundering risks](https://www.fatf-gafi.org/en/publications/Fatfgeneral/FATF-launches-National-Risk-Assessment-toolkit-to-help-countries-identify-greatest-money-laundering-risks.html) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [July 2025 National Risk Assessment of Money Laundering and](https://assets.publishing.service.gov.uk/media/6877be59760bf6cedaf5bd4f/National_Risk_Assessment_of_Money_Laundering_and_Terrorist_Financing_2025_FINAL.pdf) - [Legislation](https://www.legislation.gov.uk/ukdsi/2026/9780348285178/pdfs/ukdsi_9780348285178_en.pdf) - [Gibraltar Country Guide | Elliptic](https://www.elliptic.co/country-guides/gibraltar) - [The Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2025](https://www.legislation.gov.uk/uksi/2025/1182/made) - [The Financial Services (Gibraltar) (Amendment) (EU Exit) ...](https://www.legislation.gov.uk/uksi/2022/1157/pdfs/uksiem_20221157_en.pdf) - [Market access arrangements for financial services between the UK and Gibraltar](https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/871724/Consultation_for_publication_-_Market_access_between_UK_and_Gibraltar.pdf) - [The Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations 2024](https://www.legislation.gov.uk/uksi/2024/1158/made) - [Petfre (Gibraltar) Limited - Regulatory sanctions](https://www.gamblingcommission.gov.uk/public-register/business/detail/actions/39544) - [Enforcement Actions | FinCEN.gov](https://fincen.gov/news-room/enforcement-actions?fi=) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [Crypto-assets - Finance - European Commission](https://finance.ec.europa.eu/digital-finance/crypto-assets_en) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [DLT and tokenisation: paving the way for an ‘internet of value’ - European Commission](https://finance.ec.europa.eu/news/dlt-and-tokenisation-paving-way-internet-value-2026-04-21_en) - [Explanatory Framework for Adequacy Discussions Section I2: Gibraltar Adequacy](https://assets.publishing.service.gov.uk/media/5e6a294986650c7276a565ef/I2__-_Gibraltar_Adequacy_Referential_.pdf) - [Virtual Assets](https://www.fatf-gafi.org/en/topics/virtual-assets.html) - [JULY 2025 The Road to Crypto Regulation](https://www.chainalysis.com/wp-content/uploads/2025/06/the-road-to-crypto-regulation-part-release.pdf?mkt_tok=NTAzLUZBUC0wNzQAAAGbcgpA7NF2y9pPQkh3cu8n25w53L74RgbObzSMnm9vS_sFU2z4gx11VsydgTyZi_tc4xRx0JvdvKNCU85rYC6n1XreeaMEYjJ5tX1FVq5lEEPh) - [Blockchain and Distributed Digital Ledger Technologies (RP2025) | Interoperable Europe Portal](https://interoperable-europe.ec.europa.eu/collection/rolling-plan-ict-standardisation/blockchain-and-distributed-digital-ledger-technologies-rp2025) - [UK Maritime Services Ban and Oil Price Cap Industry Guidance - GOV.UK](https://www.gov.uk/government/publications/uk-maritime-services-ban-and-oil-price-cap-industry-guidance/uk-maritime-services-ban-and-oil-price-cap-industry-guidance) - [Russian Harmful Foreign Activities Sanctions | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/russian-harmful-foreign-activities-sanctions) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [Office of Financial Sanctions Implementation – News and updates from the Office of Financial Sanctions Implementation](https://ofsi.blog.gov.uk/) - [Enforcement – Office of Financial Sanctions Implementation](https://ofsi.blog.gov.uk/tag/enforcement/) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [General Licence – Publication Notice General licence - INT/2026/8893924](https://assets.publishing.service.gov.uk/media/699d537f882eb23165f12782/Maritime_Mutual_Wind_Down_PN_Final.pdf) - [Russia sanctions: statutory guidance - GOV.UK](https://www.gov.uk/government/publications/russia-sanctions-guidance/russia-sanctions-guidance) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Office of Financial Sanctions Implementation - GOV.UK](https://www.gov.uk/government/organisations/office-of-financial-sanctions-implementation) - [Tobacco smuggling between Gibraltar and Tangier: call for strengthening of customs service | The National Archives](http://discovery.nationalarchives.gov.uk/details/r/C2684159) - [Organized Crime Plundering West Africa, Says UNODC Report](https://www.unodc.org/unodc/en/press/releases/2009/July/organized-crime-plundering-west-africa-says-unodc-report.html) - [Cigarette Smuggling Still Booming | OCCRP](https://www.occrp.org/en/project/tobacco-underground/cigarette-smuggling-still-booming) - [Big Tobacco Smuggling - ICIJ](https://www.icij.org/investigations/big-tobacco-smuggling/) - [Tobacco companies linked to criminal organizations in lucrative cigarette smuggling - ICIJ](https://www.icij.org/investigations/big-tobacco-smuggling/tobacco-companies-linked-criminal-organizations-lucrative-cigarette-smuggling/) - [Philip Morris’ Mafia connections - ICIJ](https://www.icij.org/investigations/big-tobacco-smuggling/philip-morris-mafia-connections/) - [Big Tobacco Smuggling Archives - ICIJ](https://www.icij.org/tags/big-tobacco-smuggling/) - [The Financial Services (Miscellaneous Amendments) ...](https://www.legislation.gov.uk/uksi/2022/1223/pdfs/uksiem_20221223_en.pdf) - [The Financial Services (Gibraltar) (Amendment) (EU Exit) ...](https://www.legislation.gov.uk/uksi/2024/1158/pdfs/uksiem_20241158_en_001.pdf) - [1 Anti-money laundering and counter-terrorist financing measures Guernsey](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/MONEYVAL-MER-Guernsey.pdf.coredownload.inline.pdf) - [Financial Services Act 2021](https://www.legislation.gov.uk/ukpga/2021/22/notes/division/12/index.htm) - [The Gibraltar (Miscellaneous Amendments) (EU Exit) Regulations 2019 No. 680](https://www.legislation.gov.uk/ukdsi/2019/9780111180594/regulation/8/data.xht?view=snippet&wrap=true) - [lfg real estate (uk) limited - Companies House](https://find-and-update.company-information.service.gov.uk/company/OE032869/persons-with-significant-control) - [Gibraltar: Sharing beneficial ownership information - GOV.UK](https://www.gov.uk/government/publications/gibraltar-sharing-beneficial-ownership-information) - [GIBRALTAR (UK) LTD overview - Companies House - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/02902281) - [MONOLAT VENTURES LIMITED persons with significant control - Find and update company information - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/OE014408/persons-with-significant-control) - [buttonwood holdings limited - Companies House](https://find-and-update.company-information.service.gov.uk/company/OE025725/persons-with-significant-control) - [GIBRALTAR DIRECT LIMITED overview - Companies House](https://find-and-update.company-information.service.gov.uk/company/09738893) - [BP (GIBRALTAR) LIMITED overview - Companies House](https://find-and-update.company-information.service.gov.uk/company/00554057) - [gibraltar general partner limited - Companies House - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/06023395) - [RAPID (GIBRALTAR) overview - Companies House - GOV.UK](https://find-and-update.company-information.service.gov.uk/company/FC029753) - [RIKAS LIMITED persons with significant control ... - Companies House](https://find-and-update.company-information.service.gov.uk/company/OE005904/persons-with-significant-control) - [Money Laundering Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2) - [ECSH31555 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh31555) - [HM Treasury Advisory Notice: High Risk Third Countries - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/hm-treasury-advisory-notice-high-risk-third-countries) - [High-risk third countries](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/high-risk-third-countries) - [Money Laundering Advisory Notice: June 2026 - GOV.UK](https://www.gov.uk/government/publications/money-laundering-advisory-notice-high-risk-third-countries--2/money-laundering-advisory-notice-high-risk-third-countries--2) - [HM Treasury publish updated list of high risk third jurisdictions](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/hm-treasury-publish-updated-list-of-high-risk-third-jurisdictions) - [The Money Laundering and Terrorist Financing (High-Risk Countries) (Amendment) Regulations 2023](https://www.legislation.gov.uk/uksi/2023/704/made) - [The Money Laundering and Terrorist Financing (High-Risk ...](https://www.legislation.gov.uk/uksi/2023/704/pdfs/uksiem_20230704_en_001.pdf) - [ECSH64830 - Schedule 3ZA - High-Risk Third Countries - HMRC internal manual - GOV.UK](https://www.gov.uk/hmrc-internal-manuals/economic-crime-supervision-handbook/ecsh64830) - [Rank Interactive (Gibraltar) Limited - Licence summary](https://www.gamblingcommission.gov.uk/public-register/business/detail/57924) - [Search results for gambling businesses](https://www.gamblingcommission.gov.uk/public-register/businesses/results?business-search=Grace+Media+(Gibraltar)+Limited) - [LiveScore Betting and Gaming (Gibraltar) Limited - Licence summary](https://registers.gamblingcommission.gov.uk/56859) - [Gambling Commission website](https://www.gamblingcommission.gov.uk/) - [Remote sector guidance](https://www.gamblingcommission.gov.uk/licensees-and-businesses/sectors/sector/remote) - [News - Gambling Commission](https://www.gamblingcommission.gov.uk/news-action-and-statistics/Consultations/remote-gambling-and-software-technical-standards-consultation) - [Petfre (Gibraltar) Limited - Licence summary](https://www.gamblingcommission.gov.uk/public-register/business/detail/39544) - [Remote gambling and software technical standards (RTS)](https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/remote-gambling-and-software-technical-standards) - [KPMG Gibraltar eSummit - Sarah Gardner speech](https://www.gamblingcommission.gov.uk/news/article/kpmg-gibraltar-esummit-sarah-gardner-speech) - [HM Treasury national risk assessment 2025](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/hm-treasury-national-risk-assessment-2025) - [Rank Interactive (Gibraltar) Limited - Domain names](https://www.gamblingcommission.gov.uk/public-register/business/detail/domain-names/57924) - [National risk assessment of money laundering and terrorist financing 2025 - GOV.UK](https://www.gov.uk/government/publications/national-risk-assessment-of-money-laundering-and-terrorist-financing-2025) - [HM Treasury’s national risk assessment of proliferation financing](https://www.gamblingcommission.gov.uk/licensees-and-businesses/notice/hm-treasurys-national-risk-assessment-of-proliferation-financing) - [Anti-money laundering responsibilities for gambling businesses](https://www.gamblingcommission.gov.uk/licensees-and-businesses/page/for-all-other-gambling-businesses-aml-responsibilities) - [The money laundering and terrorist financing risks within the British gambling industry - Executive Summary](https://www.gamblingcommission.gov.uk/guidance/The-money-laundering-and-terrorist-financing-risks-within-the-British-gambling-industry/1-Executive-summary) - [Local area risk assessments](https://www.gamblingcommission.gov.uk/licensees-and-businesses/guide/local-area-risk-assessments) - [Outcomes FATF Plenary, 11-13 February 2026](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-february-2026.html) - [Outcomes FATF Plenary, 22-24 October 2025](https://www.fatf-gafi.org/en/publications/Fatfgeneral/outcomes-FATF-plenary-october-2025.html) - [Committee of Experts on the Evaluation of Anti-Money Laundering Measures (MONEYVAL)](https://www.fatf-gafi.org/en/countries/global-network/committee-of-experts-on-the-evaluation-of-anti-money-laundering-.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/topics/mutual-evaluations.html) - [Outcomes of meetings](https://www.fatf-gafi.org/en/the-fatf/outcomes-of-meetings.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Jurisdictions under Increased Monitoring - 13 February 2026](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-february-2026.html) - [The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025](https://www.legislation.gov.uk/uksi/2025/504/made) - [The Sanctions (EU Exit) (Miscellaneous Amendments) Regulations 2025](https://www.legislation.gov.uk/uksi/2025/394/regulation/14/made) - [The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022](https://www.legislation.gov.uk/uksi/2022/123/regulation/3/made) - [Russia: list of designations and sanctions notices - GOV.UK](https://www.gov.uk/guidance/russia-list-of-designations-and-sanctions-notices) - [2022 No. 1338 OVERSEAS TERRITORIES SANCTIONS](https://www.legislation.gov.uk/uksi/2022/1338/made/data.pdf) - [The Russia (Sanctions) (Overseas Territories) Order 2020](https://www.legislation.gov.uk/uksi/2020/1571/schedules) - [The Russia (Sanctions) (Overseas Territories) (Amendment) Order 2024](https://www.legislation.gov.uk/uksi/2024/370/note/made) - [Legislation](https://www.legislation.gov.uk/uksi/2022/123/made/data.xht?fhch=ef3c87c0f552a7134cdfcb92d9d40cc6) - [UK Financial Sanctions FAQs - GOV.UK](https://www.gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs) - [Gibraltar Financial Intelligence Unit (GFIU) — Financial Sanctions Guidance](https://www.gfiu.gov.gi/sanctions) - [Gibraltar Financial Intelligence Unit (GFIU) — Financial Sanctions Guidance](https://www.gfiu.gov.gi/sanctions) - [HM Government of Gibraltar](https://www.gibraltar.gov.gi/uploads/Gambling/Documents/2025NRA%20-%20FINAL.pdf) - [FATF/MONEYVAL](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-mer/Moneyval-Mutual-Evaluation-Report-Gibraltar.pdf.coredownload.inline.pdf) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Gibraltar.html) - [European Commission](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [OFSI / HM Treasury](https://assets.publishing.service.gov.uk/media/699d537f882eb23165f12782/Maritime_Mutual_Wind_Down_PN_Final.pdf) - [UK Government (legislation.gov.uk)](https://www.legislation.gov.uk/uksi/2024/370/note/made) - [Elliptic](https://www.elliptic.co/country-guides/gibraltar) - [UK Government (legislation.gov.uk)](https://www.legislation.gov.uk/uksi/2025/1182/made) Coverage gaps fim-int-2026-07-07-G001: Primary FATF publication title and … fim-int-2026-07-07-G001: Primary FATF publication title and URL specific to the 23 February 2024 grey-list removal announcement should be confirmed to replace the generic country-page citation currently used. [resolved] fim-int-2026-07-07-G002: A single authoritative source joint… fim-int-2026-07-07-G002: A single authoritative source jointly confirming both the European Commission adoption date (10 June 2025) and the legal entry-into-force date (5 August 2025) for the Gibraltar EU high-risk delisting would remove the current two-source reconciliation dependency. [resolved] fim-int-2026-07-07-G003: Evidence is needed on whether the M… fim-int-2026-07-07-G003: Evidence is needed on whether the Maritime Mutual Gibraltar insurance wind-down has fully concluded or whether alternative underwriters have filled the resulting Russia-exposed vessel coverage gap. [resolved] fim-int-2026-07-07-G004: A searchable public GFSC enforcemen… fim-int-2026-07-07-G004: A searchable public GFSC enforcement-notices archive, comparable to peer regulators such as the Guernsey Financial Services Commission, would allow continuous verification of case-level supervisory outcomes between MONEYVAL assessment cycles. [resolved] fim-int-2026-07-07-G005: Primary-source confirmation of the … fim-int-2026-07-07-G005: Primary-source confirmation of the specific 17 April 2024 UK secondary-legislation instrument cited for the Gibraltar Overseas Territories Order carve-out would strengthen the structural sanctions-divergence claim. [resolved] fim-int-2026-07-13-G001: No sourced material located for Mex… fim-int-2026-07-13-G001: No sourced material located for Mexico (MX) this cycle in the Tier-D jurisdiction sweep. [resolved] fim-int-2026-07-13-G002: No sourced material located for Col… fim-int-2026-07-13-G002: No sourced material located for Colombia (CO) this cycle in the Tier-D jurisdiction sweep. [resolved] fim-int-2026-07-13-G003: A second distinct TBML corridor bey… fim-int-2026-07-13-G003: A second distinct TBML corridor beyond the historic Cambodia/Poipet corridor (e.g. UAE or LatAm trade-triangle) could not be freshly sourced this cycle. [resolved] fim-int-2026-07-13-G004: No named enforcement action with a … fim-int-2026-07-13-G004: No named enforcement action with a specific fine or DPA amount was located this cycle. [resolved] fim-int-2026-07-13-G005: D6 (Compliance Technology and Activ… fim-int-2026-07-13-G005: D6 (Compliance Technology and Active Defence) coverage remains thin — no fresh FinCEN, FCA/JMLSG or MAS RegTech guidance was located this cycle. [resolved] fim-int-2026-08-08-G001: No GI-specific enabler-jurisdiction… fim-int-2026-08-08-G001: No GI-specific enabler-jurisdiction (D3) finding located this cycle; professional-facilitator role in Gibraltar's fund/company services sector not assessed. [resolved] fim-int-2026-08-08-G002: No GI-specific conflict-finance (D4… fim-int-2026-08-08-G002: No GI-specific conflict-finance (D4) finding located this cycle. [resolved] fim-int-2026-08-08-G003: Tier D jurisdiction checks (KH/LA/M… fim-int-2026-08-08-G003: Tier D jurisdiction checks (KH/LA/MX/CO) awaiting primary source (transient, not a no-source structural gap) — not resolved this cycle given GI-bound dispatch scope. [resolved] fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): The precise legal text of LN 147/LN 220 (trust carve-out from the UBO register) was not independently retrieved this cycle; only T3 secondary commentary corroborates the reversal. [resolved] fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): The Virtual Asset Arrangements extension of the Financial Services Act 2019 rests on a sole T4 vendor source; no primary GFSC publication was retrieved this cycle. [resolved] fim-int-2026-08-20-G003: Tier-D watch jurisdictions (KH/LA/M… fim-int-2026-08-20-G003: Tier-D watch jurisdictions (KH/LA/MX/CO) were not actively searched this cycle as the run was GI-scoped by union-dispatch design. [resolved] fim-int-2026-08-20-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-08-20-G004 ({'scheme': 'financial_integrity', 'value': 'D3'}): No D3 (Enabler Jurisdictions) or D4 (Conflict Finance) material was identified this cycle for Gibraltar. [resolved] fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): GFIU reporting-recipient, deadline and moratorium-period detail for VASP suspicion reporting was not reached within this cycle's search budget. [resolved] fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): Crypto-specific sanctions designation/freeze mechanics under Gibraltar's Sanctions Act 2019 (as amended 2024, 2026) were not independently verified this cycle. [resolved] fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-04-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): Substantive content of the Financial Services (Payment Services)/(Electronic Money) (Amendment) Regulations 2026 (2026/224, 2026/225) was not retrieved this cycle; only the instruments' existence and date are confirmed. [resolved] fim-int-2026-10-06-G001: Open findings on EMI third-party re… fim-int-2026-10-06-G001: Open findings on EMI third-party reliance (POCA s.23), eligible-introducer conditions (GFSC ch.5), and VASP transfer-regulation detail (LN 2026/134, LN 2026/147) lack verbatim-quote admission and were not promoted to structured_claims; a verbatim-source pass would allow Confirmed-tier claims on outsourcing liability and VASP perimeter scope. [resolved] fim-int-2026-10-06-G002: GFSC AML/CFT/CPF Guidance Notes v13… fim-int-2026-10-06-G002: GFSC AML/CFT/CPF Guidance Notes v13.0 (Dec 2022) formal withdrawal status is unconfirmed; several R-numbered guidance references (e.g. MLRO location) may be superseded by sectional updates (Oct 2024) but no GFSC statement of withdrawal was located. [resolved] fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): The successor instrument (LN.2026/134) replacing GI's crypto travel-rule regulations (revoked effective 15 July 2026) was not retrieved this cycle; its substantive AML content for virtual-asset transfers is unconfirmed. [resolved] fim-int-2026-10-18-G002: Tier D watch jurisdictions (KH, LA,… fim-int-2026-10-18-G002: Tier D watch jurisdictions (KH, LA, MX, CO) were not reached this cycle because the pooled union search budget was concentrated on GI. [resolved] fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-10-18-G003 ({'scheme': 'financial_integrity', 'value': 'D8'}): No GFSC primary-source notice formalising the Bullish Group tokenised-securities approval was independently retrieved this cycle; the finding rests on the company's own announcement. [resolved] fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No domain findings located this cycle for D2 (beneficial ownership), D3 (enabler jurisdictions) or D4 (conflict finance) specific to Gibraltar; treated as coverage gap given narrow 7-day window and pooled search budget, not confirmed no-change. [open] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D1'}): Substantive content (penalty quanta, procedure) of the new Sanctions Civil Enforcement Regulations 2026 is assessed at Probable confidence pending consolidated GFSC/GFIU civil-penalty tariff guidance. [open] fim-int-2026-10-25-G003: Tier-D (KH/LA/MX/CO) checks were no… fim-int-2026-10-25-G003: Tier-D (KH/LA/MX/CO) checks were not performed this cycle; this is a budget-driven gap, not a finding of no material change. [open] fim-int-2026-11-01-G010 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G010 ({'scheme': 'financial_integrity', 'value': 'D6'}): Compliance-technology supervisory expectations (CT1) could not be confirmed at a T1 source within search budget. [open] fim-int-2026-11-01-G011 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G011 ({'scheme': 'financial_integrity', 'value': 'D4'}): Cross-firm fraud/mule-account duties (FRA1) could not be confirmed at a T1 source within search budget. [open] fim-int-2026-11-01-G012 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G012 ({'scheme': 'financial_integrity', 'value': 'D7'}): Information-sharing gateways and UWO/production-order response deadlines (SAR3) could not be confirmed at a T1 source within search budget. [open] fim-int-2026-11-01-G013 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G013 ({'scheme': 'financial_integrity', 'value': 'D7'}): Periodic AML-audit/vetting cycle specifics (GOV2) could not be confirmed at a T1 source within search budget. [open] fim-int-2026-11-01-G014 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G014 ({'scheme': 'financial_integrity', 'value': 'D5'}): No research items found this cycle for D5 (Crypto/Digital Assets/Financial Innovation) or D8 (Commercial Activity) in the financial_crime domain research block. [open] fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G001 ({'scheme': 'financial_integrity', 'value': 'D6'}): Compliance-technology supervisory expectations (CT1) could not be confirmed at a T1 source within the search budget. [open] fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): Cross-firm fraud/mule-account duties (FRA1) could not be confirmed at a T1 source within the search budget. [open] fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G003 ({'scheme': 'financial_integrity', 'value': 'D7'}): Information-sharing gateways and UWO/production-order response deadlines (SAR3) could not be confirmed at a T1 source within the search budget. [open] fim-int-2026-11-01-G004 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G004 ({'scheme': 'financial_integrity', 'value': 'D7'}): Periodic AML-audit/vetting cycle specifics (GOV2) could not be confirmed at a T1 source within the search budget. [open] fim-int-2026-11-01-G005 ({'scheme': 'financial_integrity', '… fim-int-2026-11-01-G005 ({'scheme': 'financial_integrity', 'value': 'D7'}): Supervisory Bodies (Sanctions) (Enforcement) Regulations 2025 may supersede the 2017 Powers Regulations; this consumer has not researched the successor instrument's enforcement/sanctions framework directly, only identified it as a candidate via an unrouted research lead. [open] FIM-GAP-001 (D3): MONEYVAL's assessment found that in the ma… FIM-GAP-001 (D3): MONEYVAL's assessment found that in the majority of cases, sanctions imposed by Gibraltar's supervisory authorities for AML/CFT breaches were not proportionate or dissuasive, undermining the deterrent effect of an otherwise technically-compliant framework. FIM-GAP-002 (D1): Assessors found no evidence that Gibraltar… FIM-GAP-002 (D1): Assessors found no evidence that Gibraltar has ever frozen assets or transactions as a result of proliferation-financing targeted financial sanctions, and private-sector (particularly DNFBP) awareness of PF-TFS obligations was assessed as low compared to terrorist-financing TFS awareness. FIM-GAP-003 (D3): Gibraltar authorities were found to make a… FIM-GAP-003 (D3): Gibraltar authorities were found to make a low number of outgoing mutual legal assistance requests relative to the cross-border, complex nature of the proceeds of crime affecting the jurisdiction, raising doubts about proactive pursuit of foreign-predicate asset recovery. FIM-GAP-004 (D6): Publicly surfaced material on GFSC-specifi… FIM-GAP-004 (D6): Publicly surfaced material on GFSC-specific enforcement actions (fines, licence revocations) against individual regulated firms within the last 18 months is thin in open-source reporting; the GFSC does not appear to maintain as visible a public enforcement-notices archive as comparator regulators (e.g. Guernsey FSC), limiting independent verification of granular supervisory outcomes for this baseline. ## Evidence #### Confidence-tiered claims No numerical e-money derogation exists; SDD under s.16 is constrained by s.16(5) NRA geographic precedence, barring SDD for customers connected to Spain. [[Source 1]](#sec-sources) Probable · 1 source Spain can never be rated Low and no Spain-connected customer may receive SDD; Morocco may not be rated Low; funds from Spain or Morocco must be categorised as high risk subject to additional risk-based controls. [[Source 1]](#sec-sources) Probable · 1 source Compensating measures mandatory where customer not physically present, e.g. additional documents, certification, or first payment through an account in the customer's name at a credit institution. [[Source 1]](#sec-sources) Probable · 1 source Five years record retention covering CDD copies including eID data and transaction records. [[Source 1]](#sec-sources) Probable · 1 source The Gibraltar legal entity providing an account owns the AML risk and CDD/EDD decision; reliance on a third party leaves the Gibraltar firm liable (s.23). A Gibraltar branch of a UK company has the UK company as the risk-owning legal person under UK MLRs reg 20. [[Source 1]](#sec-sources) Probable · 1 source The PEP test is the prominent public function, not residence; no foreign/domestic distinction; middle-ranking and junior officials excluded; every PEP relationship treated as higher risk regardless of EEA residence. [[Source 1]](#sec-sources) Probable · 1 source Commencing 15 Jul 2026, revokes onshored Regulation (EU) 2015/847; regs 6/8 require payer/payee details, verification before execution; unlinked transfers up to EUR 1,000 equivalent carry reduced info; reg 25 requires policies for restrictive measures; reg 28 requires 5-year record retention. [[Source 1]](#sec-sources) Probable · 1 source Art 198(2): UK, in respect of Gibraltar, must not weaken AML/CFT measures below Annex 17 Union acts in force at entry into force (provisional application date under art 336(4)). Annex 17 lists Directive 2015/849 as amended, AMLR 2024/1624, AMLD6 2024/1640, AMLA Regulation 2024/1620, Regulation 2023/1113. No EU market access/passport created. European Parliament consent pending (indicative plenary 14 Dec 2026). [[Source 1]](#sec-sources) Probable · 1 source Where a PEP leaves office, firm must for at least 12 months apply risk-sensitive measures until deemed no further PEP risk; s.20(2) extends s.20B to family members and known close associates as though themselves PEPs (unlike UK, which drops family/associates when the PEP leaves office). [[Source 1]](#sec-sources) Probable · 1 source Ongoing monitoring requires scrutiny of transactions against knowledge of customer, business and risk profile; PEP monitoring enhanced (s.20(1)(c)); s.17(3) requires examination of complex/unusually large/unusual-pattern/no-apparent-purpose transactions; statutory sanctions check at s.10(ca); tipping-off duties at ss.5 and 11(5)/(5A). [[Source 1]](#sec-sources) Probable · 1 source Largely Compliant on FATF Recommendation 36 (was Partially Compliant) [[Source 1]](#sec-sources) Probable · 1 source Revoked by LN.2026/134 effective 15 July 2026 [[Source 1]](#sec-sources) Probable · 1 source Sanctions Civil Enforcement Authority (Designation) Order 2026 (LN.2026/332; LN.2026/333) [[Source 1]](#sec-sources) Probable · 1 source POCA (as amended), Sanctions Act 2019, Terrorism Act 2018, Crimes Act 2011, supervised by GFSC with GFIU as SAR/STR recipient; autonomous of EU AMLR/6AMLD/AMLA, assessed by MONEYVAL [[Source 1]](#sec-sources) Probable · 1 source Bullish Group GFSC approval to trade tokenised securities; PCC Amendment Act 2026 creates tokenised EIF cell-share regime; GI fintech $452M cumulative VC/PE funding across 32 companies [[Source 1]](#sec-sources) Probable · 1 source Largely Compliant on R.36 (up from Partially Compliant); 5th-round enhanced follow-up terminated [[Source 1]](#sec-sources) Probable · 1 source Civil monetary penalty track for sanctions breaches (balance of probabilities), recoverable as civil debt, established via Sanctions Civil Enforcement Regulations 2026 and Sanctions Civil Enforcement Authority (Designation) Order 2026 (both 9 September 2026) under the enabling Sanctions (Amendment) Act 2026 (9 July 2026) [[Source 1]](#sec-sources) Probable · 1 source GFSC DLT Provider licence for virtual-asset order execution, custody and staking, via a newly established Gibraltar entity [[Source 1]](#sec-sources) Probable · 1 source Relevant firms must report frozen assets and suspected sanctions breaches promptly [[Source 1]](#sec-sources) Probable · 1 source Holdings of multiple designated persons are aggregated for ownership/control purposes under the prescribed-interest test [[Source 1]](#sec-sources) Probable · 1 source Gibraltar may apply trade sanctions on movement of goods, services or technology in addition to asset-freeze measures [[Source 1]](#sec-sources) Probable · 1 source 2021 amendments explicitly name proliferation financing (PF) alongside ML/TF throughout POCA, extending CDD, risk-assessment, reporting and screening to CPF [[Source 1]](#sec-sources) Probable · 1 source 2023 amendment regulations require relevant financial businesses to conduct international sanctions screening as part of CDD [[Source 1]](#sec-sources) Probable · 1 source A UBO is a natural person owning/controlling more than 25%+1 share; otherwise Senior Managing Official is registered [[Source 1]](#sec-sources) Probable · 1 source All discrepancies on the UBO Register must be reported to the GFSC [[Source 1]](#sec-sources) Probable · 1 source The issue of new bearer shares is prohibited in Gibraltar [[Source 1]](#sec-sources) Probable · 1 source Relevant financial businesses must obtain senior management approval, establish source of wealth/funds, and apply enhanced ongoing monitoring for PEPs [[Source 1]](#sec-sources) Probable · 1 source EDD measures required for customers/transactions connected to EC/FATF high-risk third countries [[Source 1]](#sec-sources) Probable · 1 source Full CDD not required where statutory simplified due diligence conditions are met for lower-risk customers/products [[Source 1]](#sec-sources) Probable · 1 source Firms may rely on third-party CDD but remain ultimately liable for compliance [[Source 1]](#sec-sources) Probable · 1 source OFT is the Supervisory Authority under POCA for High Value Goods Dealers, Art Market Participants and Real Estate/Letting Agents; TCSPs are licensed by GFSC [[Source 1]](#sec-sources) Probable · 1 source Part 7 permission regime for all regulated financial-services activities including payment services and e-money [[Source 1]](#sec-sources) Probable · 1 source DLT Provider's business requires a Part 7 permission; penalties capped at higher of 2x benefit, GBP 1,000,000 or 5% annual turnover [[Source 1]](#sec-sources) Probable · 1 source VASPs must obtain and transmit originator/beneficiary info for transfers >= EUR 1,000 [[Source 1]](#sec-sources) Probable · 1 source Establishes GFIU; Part III sets CDD, record-keeping, reporting duties; SAR/consent regime; criminal penalties up to 14 years imprisonment [[Source 1]](#sec-sources) Probable · 1 source Automatic recognition of UN/UK/EU sanctions plus autonomous Gibraltar designations; screening duty amended 2024 [[Source 1]](#sec-sources) Probable · 1 source Omits s.8(3)-(4) Sanctions Act 2019 screening-policy provisions, recasting the freezing/disclosure duty [[Source 1]](#sec-sources) Probable · 1 source {'amount': 150000, 'currency': 'GBP'} [[Source 1]](#sec-sources) Probable · 1 source {'amount': 294479, 'currency': 'GBP'} [[Source 1]](#sec-sources) Probable · 1 source {'alvar_amount': 186038.52, 'argon_amount': 71281, 'currency': 'GBP'} [[Source 1]](#sec-sources) Probable · 1 source All 40 FATF Recommendations rated LC/C following re-rating of R.36 [[Source 1]](#sec-sources) Probable · 1 source Company management, cross-border finance, virtual assets and cyber-enabled fraud flagged as priority high-risk areas; Spain and Morocco flagged as higher-risk neighbouring jurisdictions [[Source 1]](#sec-sources) Probable · 1 source GFSC signalled forthcoming consultation paper on enhanced CDD obligations aligned with FATF R.16 updates, targeting VASPs and correspondent banking [[Source 1]](#sec-sources) Uncertain · 1 source Open access restored for corporate and legal entities; express trusts carved out from public inspection, effective 15 July 2026 [[Source 1]](#sec-sources) Probable · 1 source On-site visit provisionally scheduled October 2027; Plenary discussion expected around May 2028 [[Source 1]](#sec-sources) Probable · 1 source CDD measures applied prior to establishment of business relationship or occasional transaction [[Source 1]](#sec-sources) Probable · 1 source Relevant persons must report suspicion of ML/TF/PF to GFIU without delay; consent/moratorium regime applies [[Source 1]](#sec-sources) Probable · 1 source Disclosing a SAR/investigation likely to prejudice it is a criminal offence [[Source 1]](#sec-sources) Probable · 1 source CDD records retained for 5 years from completion of occasional transaction or end of business relationship [[Source 1]](#sec-sources) Probable · 1 source Penalty up to higher of 2x benefit derived or EUR 1 million (non-FI); up to EUR 5 million or 10% turnover (credit/financial institutions) [[Source 1]](#sec-sources) Probable · 1 source Supreme Court may require explanation of property worth over GBP 50,000 where known lawful income insufficient; false statement offence up to 2 years imprisonment [[Source 1]](#sec-sources) Probable · 1 source {'value': 5816, 'unit': 'count', 'period': '2025'} [[Source 1]](#sec-sources) Probable · 1 source {'received': 194, 'granted': 166, 'period': 'Q2 2025'} [[Source 1]](#sec-sources) Probable · 1 source