About the GFSC

The Gibraltar Financial Services Commission (GFSC) is responsible for the regulation of the financial services industry in Gibraltar in a fair and proportionate manner. We are a risk-based regulator that focuses on the authorisation, supervision, and enforcement of firms.

Our objectives are to protect consumers, protect the reputation of Gibraltar as a quality financial services centre and to promote good business across a wide range of sectors These sectors include, but are not limited to, banking, insurance, investment services, funds, distributed ledger technology (DLT) providers, virtual asset service providers, auditors, and insolvency practitioners.

Our statutory regulatory objectives are:

• The promotion of market confidence

• The reduction of systemic risk

• The promotion of public awareness

• The protection of the good reputation of Gibraltar

• The protection of consumers

• The reduction of financial crime

These objectives underpin our Mission and Vision statements and form the basis of the work we carry out.

In addition to our regulatory objectives, the GFSC maintains a set of core values which act as guidance on how we conduct ourselves. We expect all our staff to:

• Act with integrity

• Hold themselves accountable

• Be resilient

• Collaborate with our stakeholders

• Be insightful

Our Mission and Vision statements have been revised to ensure that they continue to reflect the ethos and culture of the organisation.

Our Mission is to promote good business, protect the public from financial loss and preserve Gibraltar’s good reputation as a financial services centre

Our Vision is to be an efficient, forward looking, and credible regulator, that is fair and proportionate, and works collaboratively with our stakeholders

In order to formulate an effective plan for the future, it is important to reflect on both the successes and the challenges faced in recent years. This process has proved essential in identifying strategic priorities that help place the organisation in a position to achieve our long-term goals.

Over the last three years the GFSC has faced various challenges as a result of the Covid-19 pandemic, both from an operational and a regulatory perspective. This has subsequently led to a shift in our operational approach.

We continue to adapt to the changes in market conditions, developments in particular sectors, and to existing and potential risks. Our ability to respond in these situations has been subject to challenges relating to competing priorities, key person risk and resourcing needs, access to the right technology and data, operational risks, and dependency on external parties. In light of this, we have re-prioritised our approach as required to ensure we continue to regulate financial services in Gibraltar effectively

In addition to the GFSC’s statutory objectives, our strategic plan is shaped by other responsibilities such as the continued monitoring and adoption of international standards, and the continued work with HM Government of Gibraltar (Government) towards the development and implementation of the Gibraltar Authorisation Regime (GAR).

Strategic Goals

After reflecting on the changes within the last few years, the organisation has identified four high-level strategic goals that will be our focus for the period 2023 - 2026.

1. To support Government and the financial services industry with the successful implementation of the GAR.

The GAR is a permanent market access regime which will provide financial services firms in particular sectors mutual market access between Gibraltar and the UK, replacing the current temporary provisions in place. The GAR will operate on the basis of there being alignment of regulatory outcomes between Gibraltar and the UK, as well as close cooperation between both governments and financial services regulators. In preparation for the commencement of GAR, the UK will carry out assessments of the relevant sectors to ensure there is a sufficient level of alignment. We will be supporting Government with this work, and ensuring that all the necessary policies, processes and procedures are in place before implementation.

In order to achieve this, we will ensure our supervisory plans, policies, procedures, and guidance. We will also be supporting Government in maintaining a sufficient level of legislative alignment and cooperation with the UK, with this work primarily focusing on ensuring the Gibraltar legislative framework is developed in accordance with the relevant changes being made in the UK. This applies to legislative changes made both in the interim period before the regime commences and on an ongoing basis.

Stakeholder engagement will also be a key component in the development and implementation of the GAR. The GFSC will be collaborating regularly with industry through industry associations and events, ensuring they are ready for any regulatory developments ahead. As a result of Brexit and the upcoming implementation of the GAR, it is vital that we continue to strengthen our relationship with the UK authorities. This will consist of regular meetings with the Prudential Regulation Authority (PRA) and the Financial Conduct Authority (FCA), and maintain working on initiatives collaboratively. The GFSC will also continue to contribute to the regular discussions and meetings between Government and HM Treasury in respect of the GAR.

2. To strengthen our effectiveness, proportionality, and risk-based focus as a regulator.

Our risk-based approach allows us to regulate firms in a fair and proportionate manner. The GFSC has developed and will be rolling out a Digital Transformation Strategy (DTS) that is designed to provide bespoke technology solutions that support our business strategy. The DTS aims to utilise automation to free up valuable regulatory time, enabling our regulators to focus on maintaining frequent face-to-face interactions with regulated firms and applicants.

We will be strengthening our project management team to provide support across the organisation and drive the delivery of business change, both internally and externally The team will lead on key projects and will foster continued improvement within internal decision-making processes, ensuring the delivery of organisation-wide, high-priority goals. The team will support the strategic priority of enhancing the GFSC’s authorisation process, ensuring speed to market that includes improving both the Regulated Individual application form and the internal assessment process

The GFSC will be developing sector-specific guidance and supervisory statements in the form of guidance notes, ‘Dear CEO’ letters and expectations papers. Further to this, our internal decision-making processes and sector panels will be reviewed with a view to strengthening their effectiveness. The outcomes and recommendations that arise from the internal assurance exercises

Will Feed Into This Work

After evaluating our successes and challenges in previous years, we continue to identify and learn from any legacy issues we have encountered. We intend to apply the lessons learnt across the organisation to create solutions for the future We also aim to be forward-looking and identify opportunities and potential issues in a timely manner. We will continue to monitor developments in the UK and within the international regulatory landscape and keep abreast of updates from international standard-setting bodies.

3. To continue collaboration and further strengthen our relationship with stakeholders.

Collaboration and the consolidation of relationships with our stakeholders allows us to obtain different perspectives on important issues and create effective solutions in the best interests of the jurisdiction. An example of this is the enhancement of our authorisations process which will be completed using a collaborative approach. We consulted with industry to put into practice a revised pre-application process that includes guidance on abridged business plans We will be introducing a staged approach to applications, creating a more manageable application process that will facilitate increased speed to market.

A key priority is maintaining our approach on consumer awareness and education. This is a vital component to one of our statutory objectives, the protection of consumers. We will continue to deliver and further develop our Moneywise consumer awareness programme, organising in-person events for students and the more financially vulnerable members of the community. We will also continue developing our Moneywise.gi website.

Over the next three-year period, we plan to enhance our overall level of stakeholder engagement and include more frequent collaboration To support future engagement and enhance regulatory expertise and commercial awareness within the organisation, we also plan to increase levels of internal training and the number of secondments to regulated firms. We are also working on a consultation on SLA’s, speaking to the marketplace on how they can be made more meaningful, efficient and useful.

The importance of effective regulation and supervision with respect to anti-money laundering and combating the financing of terrorism (AML/CFT) cannot be understated. With this in mind, we will continue to deliver an enhanced supervisory plan for AML/CFT and continue to support the jurisdiction in relation to the ongoing MONEYVAL/Financial Action Task Force (FATF) assessments

4. To recruit, develop and retain a highly skilled and motivated workforce.

The efficiency and effectiveness of the GFSC is reliant on maintaining a highly skilled and motivated workforce. In order to preserve this, we will be developing an employee engagement strategy alongside a retention policy, ensuring our skilled and experienced regulators remain with the GFSC. Additionally, we will continue assessing the effectiveness of our appraisal and salary frameworks, ensuring our staff’s renumeration reflects their expertise and performance.

Another key priority is the delivery of strategic resource allocation across the organisation. We will be ensuring that resources, both financial and in terms of personnel, are appropriately allocated to the areas of the GFSC where they are most needed. We will continue horizon-scanning to ensure we are able to achieve our long-term goals.

Further investment in training and development will also be carried out over the next few years. We aim to roll out comprehensive technical training alongside development, leadership, and management training programmes to further improve the skillset of our workforce. As part of our grow your own philosophy, we want to cultivate our staff and fully support them as regulatory experts, whilst having solutions available in the case of employee retirements, and any unforeseen circumstances that could adversely impact our resources in the future.