GFSC Thematic Review on Targeted Financial Sanctions
Summary
The Gibraltar FSC has announced a thematic review of regulated entities' compliance with Targeted Financial Sanctions (TFS) requirements. The review will involve a questionnaire for all regulated entities by March 27, 2026, followed by onsite assessments for selected firms between June and December 2026.
What changed
The Gibraltar Financial Services Commission (GFSC) has launched a thematic review to assess the effectiveness of Targeted Financial Sanctions (TFS) compliance frameworks among regulated entities. This initiative aims to identify best practices and areas for improvement in preventing the flow of funds to sanctioned individuals and entities. The review will be conducted in two phases: a comprehensive questionnaire for all entities under the GFSC's AML/CFT/CPF remit, due by March 27, 2026, and subsequent onsite assessments for a selected group of firms between June and December 2026.
Regulated entities must complete the TFS thematic questionnaire by March 27, 2026. Selected firms will be notified for onsite assessments scheduled for the latter half of 2026. The GFSC's objective is to support entities in meeting their obligations and reinforce Gibraltar's commitment to regulatory standards and global cooperation. While no direct penalties are mentioned for non-compliance with the review process itself, effective TFS compliance is a core regulatory responsibility, and findings may inform future supervisory actions.
What to do next
- Complete the TFS thematic questionnaire by March 27, 2026
- Prepare for potential onsite assessments between June and December 2026
Source document (simplified)
News
Thematic Review Announcement: Targeted Financial Sanctions
17 Feb 26
In an increasingly interconnected financial landscape, Targeted Financial Sanctions (TFS) play a crucial role in safeguarding the integrity of the global financial system. Effective TFS compliance helps prevent the flow of funds to sanctioned individuals, entities, and regimes—protecting our jurisdiction, supporting international security efforts, and ensuring regulated entities uphold their regulatory responsibilities.
Today, we are launching a thematic review of regulated entities compliance with TFS requirements. This review aims to:
- Assess the effectiveness of current TFS frameworks across regulated entities,
- Identify good practices and areas for improvement, and
- Strengthen our collective defences against financial crime. The Review Will Take Place in Two Phases
Phase 1 – TFS Thematic Questionnaire
In the first phase, all regulated entities that fall under the GFSC’s AML/CFT/CPF regulatory remit. Will be asked to complete a comprehensive questionnaire available through the GFSC Portal. This exercise is designed to help us build an accurate picture of how TFS controls are being implemented across the industry. Regulated entities will have until 27 March 2026 to submit their responses, after which we will analyse the findings and publish a Phase 1 thematic report summarising key observations and trends.
Phase 2 – TFS Focused Onsite Assessment
Following the questionnaire stage, a selected group of regulated entities will undergo more detailed onsite reviews. Selections will be based on factors such as risk exposure and the materiality of the firm’s operations. These onsite assessments, scheduled between June and December 2026, will allow us to examine TFS frameworks in practice and understand how policies and controls operate daytoday. A separate Phase 2 report will be issued once this phase is completed in order to highlight key trends and common findings, as well as to reinforce best practices in TFS compliance.
Our objective is to support regulated entities in meeting these obligations while reinforcing Gibraltar’s commitment to high regulatory standards and global cooperation.
Should you have any questions regarding the Thematic Review, email us at [email protected].
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