An Update from the JFSC – You Have Been Warned.

I attended the JCOA October Presentation where the JFSC provided an Update on their work and plans through to 2017.

The presentation was informative and certainly gave an insight into:

The Key messages provided by Roy Geddes and Anita Matthews of the JFSC were as follows:

Key examination theme has been AML in 2016 and will continue in the early part of 2017.

Moving forward examination themes later in 2017 will move towards GOVERNANCE of regulated entities and TREATING YOUR CUSTOMER FAIRLY.

Firms were reminded that they must be candid with the JFSC whether whilst an examination is in progress or generally and that it is an offence to mislead the JFSC which includes withholding material information.

In terms of customer due diligence, the JFSC made particular comment that regulated firms do not obtain and understand the rationale for customers using Jersey as a jurisdiction.

It is worth noting that findings from 2015 TCB and FSB examinations as reported by the JFSC included poor governance around AML BRAs and strategies. This trend appears to have continued into 2016.

Firms were reminded of the JFSC’s revised approach to risk as stated in the JFSC Risk Overview document published in June 2016 as recently supplemented by its Risk Severity Survey Results in September 2016 which will play a large part in the selection of firms for examination.

Please let me know if you want to talk about any of these matters.

Kind regards

Gary

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