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sentinel. Gibraltar's AML/CFT framework for the payments context is anchored in the Proceeds of Crime Act 2015 (POCA), the Terrorism Act 2018 and subsidiary regulations, supervised by the GFSC (for financial firms) with the GFIU as FIU and the OFT for certain DPMS sectors. The crypto Travel Rule is in force via POCA (since 22 March 2021). A 2025 National Risk Assessment was completed; MONEYVAL last evaluated Gibraltar in 2019 (terminating 5th-round follow-up after substantial AML/CFT enhancements, contributing to EU/grey-list removal), with the next MONEYVAL evaluation due 2027. Carried as Sentinel position; no original illicit-finance analysis performed.
Also per Sentinel, the crypto Travel Rule has been in force in Gibraltar via POCA since 22 March 2021, with an 18-month grace period to September 2022. Gibraltar completed its most recent National Risk Assessment in 2025 and is preparing for the next MONEYVAL evaluation in 2027 under revised FATF standards; MONEYVAL terminated its 5th-round follow-up after substantial AML/CFT enhancements, supporting Gibraltar's grey-list removal. The AML supervisory structure underpins correspondent-banking access and the jurisdiction's reputational standing.
Outlook
The next MONEYVAL evaluation in 2027 under revised FATF standards is the defining forward AML item, following the completed 2025 NRA. Grey-list removal and the improving compliance trajectory support correspondent-banking and counterparty acceptance. These threads carry illicit-finance significance flagged to FIM, which holds original analytical responsibility; WPM carries only the Sentinel position.
no periodic updates on record for this sub-brief
Sources and findings (10)
- T3MemberCheck (AML/CFT Gibraltar) / GFSC AML page — sentinel. POCA 2015 designates the GFSC among supervisory bodies; obliged entities owe CDD and risk-based verification duties; the GFIU gathers and disseminates financial-crime intelligence under POCA, the Terrorism Act 2018 and the Drug Trafficking Act 1995.
- T3Notabene (Travel Rule Gibraltar) — sentinel. The crypto Travel Rule has been in effect in Gibraltar since 22 March 2021 (entry into force of POCA provisions), with the GFSC monitoring compliance; an 18-month grace period ran to September 2022.
- T1HM Government of Gibraltar 2025 NRA / Financial Crime portal — sentinel. Gibraltar completed its most recent National Risk Assessment for AML/CFT/PF in 2025 and is preparing for the next MONEYVAL evaluation in 2027 under revised FATF standards; it was last evaluated by MONEYVAL in 2019.
- T3Gibraltar AML Country Update 2026 (Thomson Reuters) — sentinel. Following substantial AML/CFT enhancements, MONEYVAL terminated 5th-round follow-up reporting and the European Commission concluded Gibraltar meets standards, supporting its removal from the grey list; the Sanctions Act 2019 and Terrorism Act 2018 (incl. proliferation-financing offence) form part of the framework.
- T?FIM (sentinel.gi) per-JID baseline profile — Gibraltar — Gibraltar (British Overseas Territory) runs its own AML/CFT/CPF regime under the Proceeds of Crime Act 2015, Terrorism Act 2018 and Sanctions Act 2019, supervised by the GFSC and GFIU. It was removed from FATF increased monitoring in Feb 2024 and the EU high-risk list in June 2025, but retains structural exposure via its offshore-facing insurance, gaming and DLT/crypto sectors and a historically porous Spain frontier.
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: sourcing-thinness
- T1FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-001) — Sanctions: OFSI wind-down
- T1FIM (sentinel.gi) enforcement_action_register (issue FIM-BASE-ENF-004) — Enforcement: OFSI (HM Treasury) — Maritime Mutual Association Limited (Maritime Mutual Gibraltar) and subsidiaries
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-002) — Gap: enforcement-absence
- T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: capacity-deficit