The Gibraltar Financial Intelligence Unit uses a Suspicious Activity Reporting (SARs) online system (Themis) that allows for reporting entities in Gibraltar to submit SARs in a secure and digital format via a web-based portal. Themis is now the preferred and recommended method for the reporting of activity suspected to be associated with money laundering or terrorist financing. Reporting entities with money laundering or terrorist financing reporting obligations under the Proceeds of Crime Act (POCA) 2015 and the Terrorism Act 2018 will be requested to register their Money Laundering Reporting Officers (MLROs), nominated persons, or others with GFIU so that access can be authorised.
For access to Themis please click here.
To register with Themis as a New User requires the user to download the registration form from here and once submitted, the GFIU will provide the user with credentials to access it.
For Login and Password Guidance, please click here.
GFIU’s Privacy Notice can be downloaded here.
The organisation should only nominate Money Laundering Reporting Officers, Deputy MLROs, Compliance Officers and/or Directors (or equivalent) to report on their behalf.
A separate signed form is required for each organisation and/or individual user being registered that are obliged to report suspicion to the GFIU.
Forms must be signed by an authorised signatory.
Scanned copies of the signed form will be accepted.
It is important to notify the GFIU (by phone or email to email@example.com) of when a user has left the organisation so that their access can be removed in order to maintain the security of sensitive information.
Any reports submitted to the GFIU should only be to report suspicious financial transactions or activity. Suspicious Activity Reports should not be used to report a fraud or an attempted fraud. This should be reported to the Royal Gibraltar Police.
Manual SARs will be accepted in special circumstances and can be downloaded here.
Please note that it is the user’s responsibility to adhere to the Themis User Manual and best practices provided with the log in credentials to ensure the integrity and security of the system.