Do not forget that for any new outsourcing arrangements from 1 June 2017, firms need to consider the JFSC new Outsourcing Policy.
On 1 March 2017, the JFSC introduced a new Outsourcing Policy, applicable to registered persons in Jersey, such as trust companies, investment managers and fund services businesses. The modified outsourcing policy will:
- Take effect from 1 June 2017 for new outsourcing arrangements.
- Apply to all existing outsourcing arrangements from 1 June 2018.
Registered persons will remain responsible and accountable to the JFSC and must:-
- Have a written outsourcing agreement
- Make a business risk assessment
- Undertake due diligence on the service provider
- Consider conflicts of interests and jurisdictional risks
- Have appropriate termination provisions and contingency plans
- Complete the JFSC Outsourcing Notification Form
Comsure has offered some thoughts on outsourcing in the past – as indicated blow
Please do call Comsure if you need any help in considering the above matters