First Jersey prosecution for failure to report suspicious activity:

Acquittal for MLRO and regulated business charged with offences under the Proceeds of Crime (Jersey) Law 1999 Recent proceedings against STM Fiduciaire Limited (STM) and its Money Laundering Reporting Officer, Michelle Jardine, (Jardine) for breaches of the Proceeds of Crime (Jersey) Law 1999 (PCL) have resulted in an acquittal for all parties.

This was the first attempt at a prosecution in Jersey for failure to report potential money laundering since the provisions requiring such reports were brought in over fifteen years ago. The proceedings are said to have arisen from a visit by the Jersey Financial Services Commission (the JFSC), and concerns seemingly arising over compliance with the PCL, in particular the filing of Suspicious Activity Reports (SARs).

The visit took place in 2012, and related to failings in 2011. The JFSC apparently concluded that STM had acted swiftly to address perceived failings, and no clients were said to have been put at risk.

However, a number of years later, the decision was taken to prosecute STM and Jardine and those proceedings were heard in June 2015. The proceedings included evidence being heard from the parties, but also representatives of the JFSC and the Jersey Financial Crimes Unit (JFCU).