Gibraltar ‘cannot stand still’ on compliance efforts

Gibraltar “cannot stand still” and must “redouble” its efforts where needed to ensure continued compliance with international standards to tackle money laundering and terrorist financing.

That was the message from Nigel Feetham, the Minister for Justice, Trade and Industry, in a foreword to the newly published 2025 National Risk Assessment [NRA], which examines the Rock’s exposure to money laundering, terrorist financing and proliferation financing risks.

The document was released alongside a new Financial Crime Website, designed to provide clear and accessible information on anti-money laundering and counter-terrorist financing matters.

Developed in line with international standards set by the Financial Action Task Force, the 2025 NRA forms a central part of Gibraltar’s national strategy to protect its financial system while maintaining a proportionate regulatory framework.

“Since Gibraltar’s removal from the FATF Grey List in February 2024, we have worked tirelessly to consolidate progress and strengthen our compliance further,” Mr Feetham wrote in the foreword to the 149-page document.

“Over the past year, we have enhanced our financial crime framework through new measures such as Unexplained Wealth Orders, improved information sharing, and greater law enforcement capability.”

“We have prioritised key areas including risk-based supervision and beneficial ownership transparency.”

“Our efforts have been recognised internationally. The European Commission’s recent removal of Gibraltar from the EU list of high-risk jurisdictions reflects both our technical compliance and our determination to safeguard the integrity of our financial system.”

“But we must not stand still and must redouble our efforts where necessary.”

Mr Feetham noted that Gibraltar was currently preparing for its next Moneyval evaluation in 2027 under the revised FATF standards, which set an even higher bar for both technical and effectiveness compliance.

The NRA provides an understanding of the Rock’s risk landscape and will guide its response over the coming years.

“Further, the EU political agreement on Schengen marks a significant and positive step forward for Gibraltar,” Mr Feetham added in the foreword.

“Its implementation will have to be monitored closely for its impact on this NRA and our preparations for the forthcoming evaluation.”

“I wish to thank all our stakeholder authorities and private sector partners for their dedication to protecting Gibraltar’s reputation and ensuring the resilience of our financial system.”

“Together, we must continue to demonstrate that Gibraltar is a trusted, responsible, and proactive jurisdiction in the global fight against financial crime.”

“Our objective is clear: to prevent illicit funds from entering our economy or financial system, and safeguarding Gibraltar’s position as a secure, reputable, and attractive place to do business.”

The NRA assessment identifies key risk areas, including high-risk services such as company management, cross-border finance and virtual assets, as well as the prevalence of cyber-enabled fraud and the need for ongoing regulatory vigilance.

Gibraltar is a small finance centre which is largely UK facing in financial services and on-line gambling.

Traditional financial services products for Gibraltar had been the provision and servicing of corporate structures and private banking.

But over the last two decades these services have been in decline and replaced with on-line gambling, e-money products and, more recently, Distributed Ledger Technologies/ Virtual Assets Service Providers.

“The changing landscape of products and services necessitates that we carefully consider new and emerging risks and implement mitigation programmes to effectively mitigate the threats and vulnerabilities present in the jurisdiction,” the report states.

“Gibraltar’s client base is largely non-resident and sourced in a non face-to-face way. Both factors increase the inherent risk.”

“As a finance centre the products and services available to customers and potential customers may be accessed from anywhere in the world and many may be used in jurisdictions worldwide.”

“With the threat of use of funds to fund either terrorist organisations, terrorists or supporting terrorist activities in general, the public and private sector need to remain vigilant to the use of their products and service in countries or areas close to conflict zones or those where there is a linkage to terrorist activities.”

Since Gibraltar’s removal from the FATF grey list, the Government has significantly strengthened the capability of law enforcement agencies by increasing resources and delivering specialist training to enhance the investigation of complex financial crime.

Given Gibraltar’s small size, the most complex drug-related and money laundering cases involve cross-border elements and sophisticated methodologies, necessitating close cooperation with overseas counterparts.

The Rock’s priority is to ensure enhanced inter-agency coordination, that cases of suspicious activity are thoroughly investigated and pursued by local agencies, and that the evidence can support successful prosecutions where offences are identified.

National Coordinator, Attorney General Michael Llamas, said: “This National Risk Assessment reflects Gibraltar’s commitment to a collaborative understanding of money laundering, terrorist financing and proliferation financing threats.”

“It provides Gibraltar with a clear view of its risk landscape and serves as a valuable tool for both policymakers and regulated entities.”

“The launch of the new Financial Crime Website ensures these findings are accessible and will support a culture of transparency and compliance.”

The announcing the publication of the NRA document, the Government reminded all relevant individuals and entities, particularly those subject to the Proceeds of Crime Act 2015, that they are legally required to consider the findings of the 2025 NRA when assessing their own exposure and implementing appropriate controls.