Gibraltar
Overview
Gibraltar’s core AML/CFT/CPF framework is anchored in the Proceeds of Crime Act 2015, supported by terrorism, sanctions, supervisory and beneficial-ownership legislation. In 2026 the Sanctions Act 2019 was amended to add a civil sanctions-enforcement framework, followed by implementing regulations and designation of the Gibraltar Regulatory Authority as the civil enforcement authority.
Beneficial-ownership and legal-person transparency obligations are integrated through POCA and the Register of Ultimate Beneficial Owners framework, with sector registration and supervision tied back to the official Gibraltar legislation corpus.
SAR reporting is routed to the GFIU under POCA and related legislation. GFIU publications and Gibraltar’s national financial-crime pages provide the current institutional/reporting evidence layer.
Compliance Calendar2
Requirement
Suspicious Activity Report (SAR)
Authority / Report toGibraltar Financial Intelligence Unit (GFIU)
Deadline / triggerEvent-driven; report promptly under the applicable statutory process. A single cross-sector numeric deadline is not asserted.
Requirement
- Subject scope
- Relevant persons/businesses within Gibraltar’s AML/CFT reporting framework.
- Trigger
- Knowledge, suspicion or reasonable grounds meeting the statutory disclosure/reporting threshold.
- Filing channel
- Use the current GFIU reporting process; universal cross-sector technical channel is retained as a verification gap in this record.
Impact
- Consequences of non-compliance
- Failure to disclose/report where the statutory conditions are met may carry criminal and/or regulatory consequences. Exact offence/penalty depends on the provision and sector.
- Enforcement authority
- GFIU / Royal Gibraltar Police and relevant AML/CFT supervisor.
- Operational impact
- Maintain immediate internal escalation and current GFIU filing instructions by sector.
Requirement
Business-wide AML/CFT risk assessment and controls
Authority / Report to—
Deadline / triggerOngoing; maintain risk-based systems and controls. No single universal filing date is asserted.
Requirement
- Subject scope
- Relevant regulated/obliged businesses under POCA and sector rules.
- Trigger
- Ongoing business activity and material changes in risk exposure.
- Filing channel
- Internal governance; provide during supervision as required.
Impact
- Consequences of non-compliance
- Control failures can trigger supervisory and statutory enforcement depending on sector and breach.
- Enforcement authority
- Relevant AML/CFT supervisor / competent authority.
- Operational impact
- Keep the business risk assessment aligned with customers, services, geography and delivery channels and link it to control design.
Authorities & FIU1
FATF Assessment
Measures how fully the jurisdiction has implemented FATF’s technical requirements. It does not measure practical effectiveness.
Measures whether the AML/CFT system achieves its intended results in practice. Follow-up reports do not normally replace these ratings.
Explore 40 FATF RecommendationsSee every Technical Compliance rating and what it means.+
Explore 11 Immediate OutcomesSee how FATF rates whether the AML/CFT system works in practice.+
Regulatory Timeline37
On 9 September 2026 Gibraltar issued the Sanctions Civil Enforcement Regulations 2026 and the Sanctions Civil Enforcement Authority (Designation) Order 2026. The designation order names the Gibraltar Regulatory Authority as the sanctions civil enforcement authority under section 51A of the Sanctions Act 2019.
Gibraltar enacted the Sanctions (Amendment) Act 2026 on 9 July 2026. The amendment modifies the Sanctions Act 2019 and Proceeds of Crime Act 2015 and creates statutory civil-enforcement architecture for sanctions breaches, including monetary penalties and enforcement procedures to be set by regulations.
FATF revised Recommendation 16 to standardise payment information and strengthen fraud/error controls in cross-border payments.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF amended Recommendation 1 and related interpretive material to strengthen proportionality and simplified measures under the risk-based approach.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF removed Gibraltar from Increased Monitoring after determining that the jurisdiction had completed the agreed action plan.
FATF removed Gibraltar from its list of jurisdictions under increased monitoring.
FATF revised Recommendations 4, 30, 31 and 38 and related interpretive material to make asset recovery a stronger operational priority, expand tools to trace and confiscate criminal property and improve domestic and international cooperation.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗At its February 2023 Plenary FATF revised Recommendation 25 and its Interpretive Note to strengthen transparency and beneficial-ownership requirements for trusts and similar legal arrangements, complementing the 2022 strengthening of Recommendation 24 for legal persons.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF added Gibraltar to its jurisdictions under increased monitoring.
FATF strengthened Recommendation 24 on beneficial ownership transparency for legal persons.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF amended Recommendations 1 and 2 and their Interpretive Notes so countries and covered private-sector entities must identify, assess and mitigate risks of breaches, non-implementation or evasion of proliferation-related targeted financial sanctions.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee revised its ML/TF risk-management guidelines to add principles for information exchange and cooperation between prudential and AML/CFT supervisors in authorisation, ongoing supervision and enforcement.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted detailed implementation requirements for virtual assets and VASPs in June 2019, including the application of wire-transfer information requirements commonly described as the Travel Rule. This operationalised the virtual-asset perimeter introduced through the 2018 Recommendation 15 revision.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗In October 2018 FATF revised Recommendation 15 and added the definitions of virtual asset and virtual asset service provider, formally bringing virtual-asset activity into the global AML/CFT standards architecture. Detailed implementation requirements followed in 2019.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Proceeds of Crime Act 2015 provides Gibraltar’s core money-laundering, preventive-measures, reporting and confiscation framework.
On 14 October 2015 the Committee of Ministers adopted CM/Res(2015)26 allowing Gibraltar to be evaluated by MONEYVAL and become subject to its procedures.
The Basel Committee issued Sound management of risks related to money laundering and financing of terrorism, superseding its 2001 CDD and 2004 consolidated KYC papers and integrating ML/TF risk management with prudential supervisory expectations.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted a consolidated revised set of 40 Recommendations integrating AML, CFT and proliferation-financing safeguards.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Resolution 1737 imposed binding measures concerning Iran’s proliferation-sensitive nuclear activities, including an asset freeze on designated individuals and entities. Together with the DPRK regime, it forms a foundational UN counter-proliferation targeted-financial-sanctions architecture.
No standalone Article 25 claim is made for this profile. The parent-State, constitutional and local implementation route must be verified separately.
UN Charter · Article 25 ↗Following the DPRK nuclear test, Resolution 1718 imposed binding sanctions including an asset freeze on designated persons and entities connected to the nuclear programme. It became a central UN targeted-financial-sanctions pillar for counter-proliferation financing.
No standalone Article 25 claim is made for this profile. The parent-State, constitutional and local implementation route must be verified separately.
UN Charter · Article 25 ↗FATF added a ninth Special Recommendation addressing cash couriers and cross-border movement of currency.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Egmont Group's official Member FIU Information register records Gibraltar's FIU admission date as 2004-06-01.
Resolution 1540 requires all States to adopt and enforce laws and domestic controls to prevent non-State actors from acquiring or using weapons of mass destruction and related materials. It forms a binding global legal pillar of the proliferation-financing control environment later reflected in FATF CPF standards.
No standalone Article 25 claim is made for this profile. The parent-State, constitutional and local implementation route must be verified separately.
UN Charter · Article 25 ↗The UN General Assembly adopted the United Nations Convention against Corruption on 31 October 2003. UNCAC addresses prevention of money laundering, laundering of corruption proceeds, confiscation and a dedicated asset-recovery framework; the Convention entered into force globally on 14 December 2005.
The UN depositary records territorial application/extension of 2003 UN Convention against Corruption to this profile. This is not independent State-Party status and carries no implication about sovereignty; domestic implementation remains a LOCAL evidence question.
UN Treaty Collection ↗FATF comprehensively revised its AML/CFT Recommendations, strengthening preventive measures and extending coverage.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee issued Customer due diligence for banks, setting minimum supervisory expectations for customer acceptance, identification, ongoing monitoring and risk management. It became an influential global banking KYC/CDD benchmark and was later reflected in FATF standards.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF expanded its standards to terrorist financing through eight Special Recommendations.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Resolution 1373 requires all States to prevent and suppress terrorist financing, criminalise the provision or collection of funds for terrorist acts, freeze terrorist assets without delay and prohibit making funds or financial services available to terrorists and related entities.
No standalone Article 25 claim is made for this profile. The parent-State, constitutional and local implementation route must be verified separately.
UN Charter · Article 25 ↗The Palermo Convention was adopted on 15 November 2000 and broadened the international money-laundering framework beyond drug proceeds through criminalisation and preventive measures tied to transnational organised crime. It entered into force globally on 29 September 2003.
The UN depositary records territorial application/extension of 2000 Palermo Convention to this profile. This is not independent State-Party status and carries no implication about sovereignty; domestic implementation remains a LOCAL evidence question.
UN Treaty Collection ↗The UN General Assembly adopted the International Convention for the Suppression of the Financing of Terrorism on 9 December 1999, creating the treaty framework for criminalising terrorist financing and international cooperation. It entered into force globally on 10 April 2002.
The UN depositary records territorial application/extension of 1999 Terrorist Financing Convention to this profile. This is not independent State-Party status and carries no implication about sovereignty; domestic implementation remains a LOCAL evidence question.
UN Treaty Collection ↗Resolution 1267 imposed an assets freeze and other targeted sanctions in the Taliban context and created the Security Council committee that became the foundation of the UN 1267 sanctions architecture. It is a key global precursor to modern terrorist-financing targeted financial sanctions.
No standalone Article 25 claim is made for this profile. The parent-State, constitutional and local implementation route must be verified separately.
UN Charter · Article 25 ↗FATF revised the Forty Recommendations to reflect evolving money-laundering methods and countermeasures.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Representatives of 13 financial intelligence units met in Brussels on 9 June 1995 and founded what became the Egmont Group. The milestone created the operational global network for FIU-to-FIU cooperation and exchange of financial intelligence.
Current profile relationship to the Egmont network. This does not imply membership in 1995; admission history is a separate LOCAL/STATUS fact.
Egmont Group · Member FIUs ↗FATF issued its original Forty Recommendations, establishing the first global AML standard framework.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The G7 established FATF in 1989 to examine and develop measures to combat money laundering. FATF became the central global standard-setting body whose recommendations are implemented through national and regional AML/CFT frameworks.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Vienna Convention was adopted on 20 December 1988 and created the first treaty-level international obligation to criminalise laundering conduct linked to drug-trafficking proceeds, alongside confiscation and international-cooperation measures. It entered into force globally on 11 November 1990.
The UN depositary records territorial application/extension of 1988 Vienna Convention to this profile. This is not independent State-Party status and carries no implication about sovereignty; domestic implementation remains a LOCAL evidence question.
UN Treaty Collection ↗The Basel Committee published a Statement of Principles for banks aimed at reducing the risk that banking institutions would be used by criminals or as channels for money laundering. This helped establish the preventive and supervisory side of AML alongside the emerging criminal-law framework.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗