Revised Outsourcing Policy Consultation
In 2021, we were presented with some suggested ‘quick wins’ for Industry. One of the quick wins proposed, was a revision to our current Outsourcing Policy (OSP) and Guidance Notes.
Summary of changes:
- where a Service Provider performs outsourced activity in the form of telecommunication services on behalf of a business, such outsourced activity is not caught
- specific guidance is provided where a service provider performs outsourced activity in the form of Cloud Services
- all Supervised Persons must comply with the Revised OSP in accordance with the new consolidated AML/CFT Handbook
- managed Trust Company Business is now exempt from the application of the Revised OSP
- the provisions of and corresponding guidance within the Revised OSP have been amended to read more clearly and simply and to reflect our current regulatory framework
More detailed information on each key change is set out in our consultation.
A working group was established through March and April 2022 to review the draft Revised OSP before going out for wider public consultation and included representatives from a range of different sectors (Banking, TCB, FSB, Legal and Digital). The collective feedback of the working group, together with our responses is included in our consultation.
We are now asking for your feedback on our Revised OSP.
Who will the Revised OSP impact?
The Revised OSP will impact any person to whom the provisions of the Revised OSP apply. The requirement for all Supervised Persons to comply with the Revised OSP represents a change of policy insofar as only regulated persons carrying on regulated business have had to comply with the current OSP and Guidance Notes to date.
We encourage you to read our consultation and respond by Wednesday 31 August 2022.
Following our consultation, we will publish feedback and issue a final form Revised OSP in October. There will then be a three-month transition period for compliance with the Revised OSP.