The Anguilla Financial Services Commission is conducting compliance inspections of licensed entities through 2025 and into 2026. The inspection programme covers onsite reviews of AML/CFT governance documentation, client due diligence records, beneficial ownership register accuracy, suspicious activity report logs, staff training records, and internal audit reports. Corporate service providers and trust service providers have been identified as priority sectors for this inspection cycle.
What Inspectors Are Looking For
Based on AFSC's stated inspection focus areas, regulated entities should expect inspectors to examine the following.
AML/CFT policies and procedures must be documented, current, and aligned with the 2025 regulatory amendments. Generic or outdated policies are a straightforward inspection finding. Policies should reflect the entity's actual risk profile and business model, not a generic template.
Client due diligence records for key relationships must demonstrate that CDD was completed at onboarding and that enhanced due diligence was applied where required. Gaps in CDD documentation — particularly for higher-risk clients — will attract scrutiny.
BO register accuracy is a specific focus point. Inspectors will verify that BO registers are current, that changes have been notified to AFSC within the required timeline, and that the registered agent's filing records are consistent with the company's BO register.
Staff training records must show that AML/CFT training is current for all relevant staff. Outdated training logs — particularly where regulations changed in 2025 — are an avoidable gap.
Internal audit function is an increasing expectation. AFSC expects regulated entities to have a documented internal AML/CFT audit function that has reviewed controls within a reasonable recent period.
Announced and Unannounced Inspections
AFSC may provide advance notice of inspections or may conduct unannounced visits. Entities should maintain inspection-ready documentation at all times. Entities found to be non-compliant may face financial penalties, licence conditions, or other regulatory consequences.
What To Do Now
Review your AML/CFT policies, procedures, and controls documentation for completeness and currency. Ensure BO registers are accurate and AFSC-notified. Check that staff AML/CFT training is current and logged. Review client risk assessment and CDD records for your key client relationships. Confirm that your internal AML/CFT audit function has reviewed controls within the last twelve months.