The following AML / CFT Culture and Corporate Social Responsibility (CSR) commentary IS FULLY ENDORSED by Comsure and could not be said any better so we are wishing to spread the message though our net work– IT was Published by Malcolm Wright on December 11, 2016, on  Linkedin Head of AML, Thomson Reuters – [link […]

From the GDPR Effective Date, the GDPR will be the main instrument governing EU data protection law across all Member States and equivalent jurisdiction (Jersey and Guernsey being 2). The Directive, which is almost 20 years old, will be repealed. However, the relationship between the GDPR and some other laws remains unclear and is subject […]

ONE big difference I see regarding mentality change is that the burden of proof is reversed: If you are using data, you need to assure the required mechanisms are in place to pursue your endeavours. There is, therefore, a “documentation obligation” that kicks in, shifting the burden of proof that until now was set out […]

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 […]

Comsure’s Directors training focuses on collective and personal responsibilities.  In consideration of Personal liability, Comsure deals with directors accountabilities, and in doing so touch on the FCA/PRA Senior Managers and Certification Regime (SMCR) regime.  Also, the case below is considered.  Although the case dates back to 2012, it has some powerful reminders and tips on […]

It seems that rarely does a day goes by without a cyber-attack on a major company making the headlines and now we have the high-profile cyber-attacks of Friday 12th May. This news must now put us on alert as to the dangers of inadequate IT security. This latest NHS breach highlights the vulnerability of businesses […]

REGULATED FINANCIAL SERVICES BUSINESSES (RFSB) are used to assessing risk in areas such as Credit Risk or Market Risk.  These risks can also be (arguably) easily quantified and are usually assessed before accepting the risk, and along with quantitative and qualitative risk assessment methodologies they have proven to be useful in helping RFSBs not only […]

The Criminal Finances Act received royal assent on 27 April 2017. Among other measures, the Act introduces a new corporate criminal offence of failing to prevent the facilitation of tax evasion (CCO). The new offence concerns when an ‘associated person’, such as an employee, agent, contractor or subsidiary, facilitates the evasion of tax of a […]