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Gibraltar Jurisdiction: Identifying Risks and Vulnerabilities

The Gibraltar jurisdiction has implemented strong regulations and controls to mitigate the risk of money laundering, terrorist financing, and sanctions evasion. However, despite these efforts, there are still some risks identified that require attention and mitigation measures to be taken.

High-Risk Areas

Gibraltar’s proximity to North Africa and its connections with the UK make it vulnerable to certain high-risk areas.

Sanctions Risk

The risk that a Gibraltar transaction/structure is used to circumvent an international sanction.

Terrorist Target Risk

The risk of a terrorist attack on Gibraltar due to its connections with the UK and proximity to North Africa.

Proximity of Organised Crime Risk

The risk that organised criminal gangs operating in neighbouring countries may perceive Gibraltar as an opportunity to launder their criminal proceeds.

Medium-Risk Areas

While Gibraltar’s regulations and controls are strong, there are still some medium-risk areas that require attention.

Money Laundering (ML) in High-Value Transactions

Although CDD measures are in place, there is a risk that high-value transactions may be attractive to ML risks.

Tobacco Sales Risk

The risk that tobacco sales present an opportunity for money launderers, particularly due to the use of cash-only environments.

Low-Risk Areas

While Gibraltar has implemented strong entry standards and regulations, there are still some low-risk areas that require ongoing monitoring.

Abuse by Criminal Organisations Risk

Although Gibraltar has strong entry standards and regulations in place, there is still a low risk that criminal organisations may abuse Gibraltar-based operators.

Use of Licensed Retail Operations to Obfuscate Cash Deposits

This is the highest sub-risk identified under the Tobacco Sales category.

Threats or Vulnerabilities

Gibraltar faces several threats or vulnerabilities that require attention and mitigation measures to be taken:

• Lack of centralized local list of applicable sanctions and local awareness.
• Poor economic climate and unemployment rates in neighbouring regions contributing to the growth in illegal activity.
• Rise in Islamist extremists in North Africa seeking to retaliate against the US, UK, and their allies.