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National Strategy
Gibraltar’s National Strategy to Combat Financial Crime
HM Government of Gibraltar is committed to protecting the integrity of its financial system and economy through a comprehensive and coordinated approach to preventing and disrupting financial crime. Gibraltar’s National Strategy to Combat Money Laundering, Terrorist Financing, and Proliferation Financing reflects this commitment and aligns with international standards including those set by the Financial Action Task Force (FATF).
Oversight and Governance
The implementation of the national strategy is overseen by the National Coordinator for AML/CFT, who works across all relevant authorities to ensure effective coordination. Progress is monitored through defined performance indicators, regular updates to the NRA, and alignment with MONEYVAL and FATF expectations.
Commitment to Continuous Improvement
The financial crime landscape continues to evolve rapidly. Gibraltar remains committed to:
- Maintaining a robust, transparent, and effective anti-financial crime regime,
- Regularly updating its strategy,
- Responding proactively to new risks and typologies, and
- Enhancing its resilience and reputation as a responsible international finance centre.
National Risk Assessment
Gibraltar’s approach to combatting money laundering (ML), terrorist financing (TF), and proliferation financing (PF) is grounded in a clear understanding of the risks it faces. A cornerstone of this approach is the regular undertaking of a National Risk Assessment (NRA), a comprehensive exercise designed to assess threats, vulnerabilities, and the effectiveness of the national framework in responding to them.
Conducting an NRA is both a domestic priority and an international obligation.
Purpose of the NRA
The NRA is a strategic tool that enables Gibraltar to:
- Identify and assess the most significant ML/TF/PF threats facing the jurisdiction;
- Understand vulnerabilities across sectors, products, and services;
- Evaluate the effectiveness of preventive measures, enforcement, and supervision;
- Support evidence-based policymaking and prioritisation of resources;
- Guide regulated entities in adopting risk-based approaches to compliance.
The findings of each NRA directly inform Gibraltar’s National Strategy for Combatting Financial Crime, regulatory priorities, and legislative updates.
How Gibraltar Conducts its NRA
Gibraltar’s NRAs are conducted under the coordination of the National Coordinator for AML/CFT, with the involvement of a wide range of stakeholders, including:
- Supervisory and regulatory authorities
- Law enforcement and intelligence agencies
- Industry associations and private sector participants
- Technical experts and data analysts
Gibraltar aims to conduct a full NRA approximately every four years, with updates and targeted reviews in between as needed. This ensures that the findings remain relevant in the face of evolving threats, market developments, and technological innovation.
The most recent NRA was completed in 2025.
What Regulated Entities Need to Know
Entities subject to AML/CFT/CPF obligations must have regard to the findings of the NRA when:
- Conducting business-wide and customer-level risk assessments;
- Designing and implementing internal controls;
- Allocating compliance resources; and
- Reviewing or updating policies and procedures.
Links:
- National Risk Assessment 2025
- National Risk Assessment 2020 – Executive Summary
- National Risk Assessment 2020
- National Risk Assessment 2018
- National Risk Assessment 2016
Agencies Combatting Financial Crime
Summary of public and private stakeholders safeguarding Gibraltar’s fight against financial crime.
Political
Ministry for Justice, Trade and Industry
The Ministry leads Gibraltar’s national policy direction on financial crime. It has overarching responsibility for ensuring Gibraltar’s legal and regulatory framework aligns with international standards on anti-money laundering (AML), counter-terrorist financing (CTF), and counter-proliferation financing (CPF), including compliance with the FATF Standards.
National Coordinator for AML/CFT
The National Coordinator is responsible for coordinating Gibraltar’s national strategy and policy on AML/CFT. This role ensures a collaborate approach to combating financial crime, oversees the National Risk Assessment (NRA), and acts as the key liaison with international standard-setters and mutual evaluation bodies.
Steering Committee
Chaired by the Minister for Justice, Trade and Industry, the Steering Committee coordinates policy, legislative and other initiatives to strengthen Gibraltar’s operational frameworks in all aspects of AML/CFT/CPF.
Interagency sub-committee
Established to discuss matters of mutual interest that impact or could potentially impact the jurisdiction, its reputation, as well emerging threats and vulnerabilities relating to ML/TF/PF. It is chaired by the National Coordinator and is comprised of all relevant domestic stakeholders.
Sanctions sub-committee
Chaired by the National Coordinator, the Sanctions Sub-Committee comprises all authorities with sanctions-related responsibilities, including law enforcement, supervisory bodies, port and maritime authorities, Border and Coastguard, etc.
Stakeholders
Gibraltar Financial Intelligence Unit
The GFIU is Gibraltar’s central authority for receiving, analysing, and disseminating suspicious activity reports related to money laundering, terrorist and proliferation financing, and other predicate offences. It plays a critical role in the intelligence and prevention chain, both domestically and through international cooperation with other FIUs.
Gibraltar Financial Intelligence Unit
Royal Gibraltar Police
The RGP’s Economic Crime Unit investigates criminal offences including economic and financial crime, fraud, money laundering, and corruption. The Unit works closely with the GFIU and other authorities in identifying and prosecuting financial crime acting on intelligence received via SARs, cross-border cooperation channels and other sources. In addition, the RGP ECU works with the RGP Special Branch on TF and PF related investigations, leveraging international police to police information and intelligence sharing channels including INTERPOL.
HM Customs
HM Customs is responsible for enforcing Gibraltar’s customs and excise laws and plays an important role in interdicting illicit cross-border financial flows, smuggling, and trade-based money laundering. The HM Customs Financial Investigation team works in coordination with other law enforcement and intelligence agencies to combat financial crime, utilising its investigative and confiscation powers through civil and criminal procedures.
Office of Criminal Prosecutions & Litigation
The OCPL prosecutes criminal offences on behalf of the Crown, including those related to money laundering, terrorist financing, fraud, and sanctions violations. It ensures that financial crime cases are pursued effectively through the courts. The OCPL is also the Competent Authority for receiving and processing mutual legal assistance requests on behalf of the Attorney General.
Office of Criminal Prosecutions & Litigations
Gibraltar Financial Services Commission
The GFSC is Gibraltar’s financial regulator. It supervises banks, insurers, investment firms, and other financial institutions to ensure compliance with AML/CFT regulations. The GFSC conducts risk-based supervision, enforces regulatory standards, and takes action against non-compliance or misconduct.
Gibraltar Financial Services Commission
Office of Fair Trading
The OFT licenses and supervises real estate agents, high value dealers and art market participants, in respect of their AML/CFT obligations. It conducts inspections, offers guidance, and enforces compliance within these non-financial sectors. The OFT also collaborates with other regulatory bodies and law enforcement agencies to ensure a consistent approach to AML/CFT efforts.
Gambling Commission
Gibraltar’s Gambling Division supervises licensed gambling operators for compliance with AML/CFT regulations. It works in coordination with the GFIU and other regulators to mitigate financial crime risks within the sector.
Legal Services Regulatory Authority
The LSRA is an independent body with responsibility over the regulation of legal professionals in Gibraltar. It ensures that lawyers and law firms comply with their AML/CFT/CPF obligations through the application of a robust supervisory regime that includes onsite verification, enforcement measures, and close cooperation with other regulators and law enforcement authorities.
Legal Services Regulatory Authority
Financial Secretary
The Financial Secretary is the supervisory authority regarding AML/CFT compliance by the Gibraltar Savings Bank.
UBO Registrar
The UBO Registrar maintains the Register of Ultimate Beneficial Owners, a central mechanism for transparency and access to ownership information in line with AML/CFT standards. The Registrar also verifies data and works with authorities to support investigations involving beneficial ownership.
Companies House
Companies House is the registry for companies and other corporate entities in Gibraltar. It supports financial crime prevention through the maintenance of accurate and timely corporate data, enabling transparency and due diligence on legal persons.
Income Tax
The Income Tax Office is responsible for enforcing Gibraltar’s tax laws and plays a key role in identifying tax evasion, aggressive tax avoidance, and related financial crimes. It collaborates with other domestic and international agencies to ensure tax transparency and information exchange.
Private-Public Partnership
The Financial Liaison and Intelligence Network (FLINT) is a public-private partnership led by the GFIU. It brings together key public sector agencies, including the Royal Gibraltar Police, HM Customs, the Tax Office, and the Gibraltar Financial Services Commission, alongside a number of leading banks operating in Gibraltar.
Financial Liaison and Intelligence Network
Relevant Legislation
All relevant legislation can be found at www.gibraltarlaws.gov.gi - including all subsidiary legislation.
Some of the key legislation includes:
- Proceeds of Crime Act 2015
- Crimes Act 2011
- Sanctions Act 2019
- Terrorism Act 2018
- Counter Terrorism Act 2010
- Mutual Legal Assistance (International) Act 2005
- Mutual Legal Assistance (Council of Europe) Act 2018
- Companies Act 2014
FATF and MONEYVAL
What is the FATF?
The Financial Action Task Force (FATF) is the global standard-setting body for combatting money laundering, terrorist financing, and proliferation financing. It comprises over 200 jurisdictions through its network of regional bodies.
The FATF develops and promotes international standards to ensure a coordinated global response to illicit finance. It monitors implementation of these standards through a rigorous mutual evaluation process.
What is MONEYVAL?
MONEYVAL (The Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism) is a regional monitoring body under the Council of Europe. It is responsible for assessing the compliance of its member jurisdictions, including Gibraltar, with FATF Standards.
MONEYVAL evaluations consider both the technical compliance of a jurisdiction’s legal and institutional framework and the effectiveness of its anti-money laundering and counter-terrorist financing regime.
MONEYVAL - Committee of Experts on the Evaluation of AML/CFT
Gibraltar’s Previous Evaluation
Gibraltar was last evaluated by MONEYVAL in 2019, with the final Mutual Evaluation Report published in December 2019.
The report assessed Gibraltar’s technical compliance and effectiveness in implementing the FATF Recommendations. Key findings noted the jurisdiction’s strong regulatory framework and cooperation among competent authorities, while also identifying areas for improvement particularly in enhancing the use of financial intelligence and ensuring consistent application of risk-based supervision.
Ongoing Commitment to Compliance
Significant legislative and operational enhancements have been introduced since the 2019 assessment, and Gibraltar continues to work closely with MONEYVAL and international partners to meet evolving global standards.
The next evaluation is scheduled for 2027.