A GFSO licence is granted and kept on the strength of the compliance framework behind it, so the AML manual, the monitoring plan and the MLRO appointment are not paperwork but the thing the regulator actually inspects. Basnet Law designs and documents the anti-money laundering and compliance framework a Licensed Firm must have under the Financial Services Act 2025, the General Rulebook and the AML and Sanctions Rulebook. We build it to the standard GFSO reviews at licensing and tests in supervision. This page explains what the regime requires and how we build it.
How we help
- Draft the AML manual describing internal controls against money laundering, terrorist financing, proliferation financing, financing of unlawful organisations and sanctions non-compliance, as GFSO's published guidance expects.
- Design customer due diligence, risk rating, monitoring and record-keeping procedures that meet the AML obligations in the Financial Services Act 2025.
- Document the compliance function, its resources and reporting lines under the GEN Rulebook, with a monitoring programme.
- Write the whistleblowing policy the GEN Rulebook requires, with the six-year record retention.
- Define the Money Laundering Reporting Officer role under the GEN Rulebook and support the Approved Person application.
- Build the beneficial ownership process, using the "registrable controller" framework as the reference model, and train staff so the SEO, Compliance Officer and MLRO can demonstrate AML knowledge.
How GMC AML law works, in plain terms
The Financial Services Act 2025 designates the Regulator as "the Supervisory Authority for GMC" and makes it "responsible for regulation in relation to money laundering in GMC". The definition is wide: money laundering "is taken to include terrorist financing, the financing of unlawful organisations and sanctions non-compliance". The Act places the obligations on the Relevant Person directly: comply with AML obligations and the Rules, "conduct customer due diligence as specified in the Rules", and maintain records of due diligence, transactions and AML measures. The Regulator may deem any person a Relevant Person by written notice.
The GEN Rulebook supplies the organisational backbone. A Licensed Firm "must establish and maintain systems and controls" that ensure its affairs are managed effectively by senior management, and must review them regularly. Roles and reporting lines must be documented, key duties segregated and risk management systems maintained. The compliance function must be documented, resourced with "an adequate number of competent staff" and given unrestricted access to records and the Governing Body. Breaches must be identified, reported and recorded, and an independent internal audit function maintained. The rulebook requires "appropriate and effective arrangements" to facilitate Protected Disclosures and protect the discloser's identity, set out in written policies.
The MLRO is a Controlled Function held by a Director, Partner or Senior Manager with "day to day oversight of its compliance with the Rules in AML". The appointment is mandatory and, subject to waiver, the MLRO must be resident in GMC or Bhutan. The detailed due diligence, screening and reporting standards sit in the AML and Sanctions Rulebook, which we apply in drafting.
The regime is not limited to Licensed Firms. The following must register with GFSO as Designated Non-Financial Businesses and Professions (DNFBPs): real estate agencies, dealers in precious metals or stones, dealers in any goods sold at USD 15,000 or more, accounting, audit, insolvency or tax consulting firms, law firms and notaries, Corporate Service Providers, and non-profit organisations.
Who this is for
- Applicants at the IPA stage that must evidence systems and controls before the Financial Services Licence issues.
- Virtual asset firms, custodians and exchanges facing enhanced scrutiny on source of funds and sanctions.
- Fund managers, advisers and arrangers building a proportionate programme for a small team.
- Existing Licensed Firms remediating findings or preparing for a GFSO review.
- DNFBPs (law, accounting, real estate, high-value dealers, CSPs, NPOs) that must register with GFSO and build a proportionate programme.
How an engagement runs
- Business risk assessment: we map products, clients, geographies and delivery channels to inherent risk.
- Framework design: we draft the AML manual, compliance manual, whistleblowing policy and monitoring plan against the Act and the GEN Rulebook.
- Roles: we document the Compliance Officer and MLRO responsibilities and support their Approved Person applications.
- Implementation: we configure onboarding checklists, escalation paths and record templates, and train staff.
- Assurance: we schedule the periodic reviews the rulebook requires, so the programme stays current.
Frequently asked questions
Who is the AML regulator in GMC?
The Regulator under the Financial Services Act 2025, the Gelephu Financial Services Office (GFSO), which the Act designates as the Supervisory Authority for GMC. It is the body we build the programme for.
Does a small advisory firm need the same programme as a bank?
The obligations apply to all Licensed Firms, but the GEN Rulebook guidance says the Regulator will take account of "the nature, scale and complexity" of the business. We scale the programme without omitting mandatory elements.
Must the MLRO live in GMC?
The GEN Rulebook requires residence in GMC or Bhutan. The guidance notes the Regulator may waive the requirement in appropriate circumstances, considering the firm's compliance arrangements, and we make that case where it fits.
Can the Compliance Officer also be the MLRO?
The GEN Rulebook guidance indicates these roles would not be expected to be combined with other Controlled Functions unless independent monitoring arrangements are in place. We advise on the combination realistically open to your firm.
Talk to GMC counsel on the ground
Basnet Law Pte. Ltd. is the first law firm incorporated in the Gelephu Mindfulness City. A short conversation early in a matter usually saves time and cost later. Write to basnet@basnetgmc.com or office@basnetgmc.com with a few lines about your plans, and we will tell you plainly what is needed, how long it takes, and whether we are the right fit.
You may contact Basnet Law at basnet@basnetgmc.com or office@basnetgmc.com for any legal queries related to GMC.
