Updates to National Risk Assessments
On 23 May 2023, there was a briefing to finance industry on the progress being made on the rolling programme of National Risk Assessments (NRAs).
National Risk Assessments of Terrorist Financing
An update to the Terrorist Financing NRA was published shortly before the briefing.
Drafted as part 2 to the 2021 Terrorist Financing NRA, it improves:
- our risk understanding
- addresses gaps in our knowledge
- the understanding of terrorist financing threat
While Jersey is fortunate not to have any domestic terrorism, that does not mean it could not be an attractive place for these funds to be held or distributed.
Industry briefing on Financial Crime at the event 23 May 2023
National Risk Assessment of Legal Persons and Arrangements
Legal Persons and Arrangements (LPAs) include everything from Companies to Trusts and more obscure arrangements such as fideicommis. There was a huge dat-gathering exercise carried out with the Registry and industry to improve our understanding of:
- how different kinds of LPAs are used
- how popular they are
- potential threats and vulnerabilities
The NRA is due to be published in May.
National Risk Assessment Money Laundering 2023 update
The first Jersey NRA was published in 2020 using data gathered mainly in 2018 and 2019. It was always intended as the start of an ongoing process, and since then several more specific NRAs have been published.
The 2020 NRA covered a lot of ground, and it was recognised that some specific areas needed further analysis to give industry a greater understanding of the risk profile in areas such as Trust and Company Service providers (TCSPs), and the legal and banking sectors. This update is due to be published in June.
Combatting Financial Crime Together: Managing Higher-risk Jurisdictions; UK and Global Outlooks on Illicit Finance
On 21 March 2023, finance industry professionals received updates from an international panel of experts on how to approach the risks Jersey faces as an International Finance Centre.
Jennifer Haslett, the Head of FATF and International Branch, Sanctions and Illicit Finance Team at HM Treasury, spoke about how the UK approaches cross-border risk, and how to tailor ECDD for international clients using FATF reports and Typologies.
Watch an outline version of her presentation Financial Crime: Understanding and Managing Risk with Jennifer Haslett on YouTube.
You can also watch a question and answer section with Richard Pedley from the Government's Financial Crime Strategy Team, Financial Crime: Understanding and Managing Risk Q&A with Jennifer Haslett on YouTube.
Combatting Financial Crime Together: Proliferation Financing
On 23 February 2023, finance industry professionals received updates from Darya Dolzikova, a Research Fellow with Royal United Services Institute's Proliferation and Nuclear Policy Programme, and from the Financial Intelligence Unit, Jersey Financial Services Commission.
Proliferation financing
Watch the full interview with Darya Dolzikova providing an overview of Proliferation Financing on YouTube or access the specific subjects:
Watch Proliferation Financing, questions and answers with Darya Dolzikova on YouTube
Proliferation financing an overview by Darya Dolzikova
Financial Intelligence Unit
Detective Sergeant Mike Fitzgerald gave an update on the Financial Intelligence Unit's view on terrorist financing.
Event on Combatting Financial Crime Together: FIU, Non-Profit Organisations, AML enforcement, and typologies
On 31 January 2023, finance industry professionals were updated by representatives from the Financial Intelligence Unit, Jersey Financial Services Commission, and Government of Jersey.
Financial Intelligence Unit
Detective Sergeant Mike Fitzgerald gave an update on the new structure of the expanded Financial Intelligence Unit, following changes to the law adopted in 2022.
Jersey FIU MONEYVAL preparations and update by DS Mike Fitzgerald
FIU structure update by DS Fitzgerald on YouTube (9:59)
Non-profit organisation / charities supervision
Sam Davison and Kate Rogers from the JFSC outlined the changes to the non-profit organisation legislation and supervisory oversight to bring the Island into line with the FATF requirements to prevent terrorist financing and proliferation financing, while ensuring that the activities of the organisations are not impacted.
Non-Profit Organisations presentation, by Jersey Financial Services Commission
Non-profit organisation update by JFSC on YouTube (9:39)
Legislative changes to anti-money laundering enforcement
Dr Bastian Hertstein from Government set out changes to AML enforcement and explained the rationale behind these new laws, primarily focussing on the new Failure to Prevent offence, and Deferred Prosecution Agreements.
Increasing the effectiveness of AML enforcement in Jersey, by Dr Bastian Hertstein
Interview with Dr Bastian Hertstein on changes to AML enforcement on YouTube (11:13)
Typologies
Government's Director of Financial Crime Strategy, George Pearmain, explained what the Typologies Document was and how it could help industry spot signs of criminal activity.
Interview with George Pearmain on Typologies Document on YouTube (5:16)
Event on Combatting Financial Crime Together: Digital ID, Obliged Entities and Exemptions
On 16 November 2022, finance industry professionals were briefed by representatives from the Jersey Financial Services Commission (JFSC) and the Government.
Julie Keir, from Government, and Olenka Apperley, from the JFSC, discussed the progress being made on establishing a digital identity system in Jersey.
Adoption of Digital Identity Systems (Digital ID)
George Pearmain, Government's Director of Financial Crime Strategy then provided an update on how the Island is tackling the issue of beneficial ownership of obliged entities.
Beneficial Ownership - Obliged Entities and Access to the Central Register
Secondary Consultation re Non-Profit Organisations
On 7 November 2022, an event was held as part of the consultation on the proposed Order, which aims to bring Jersey into line with FATF standards as regards non-profit organisations (NPOs).
NPOs and charities - are you ready for the changes coming to the law?
Event on Combatting Financial Crime Together: Enhanced Due Diligence
Finance industry professionals were briefed on 19 October 2022 by representatives from the Jersey Financial Services Commission (JFSC) and the Government.
At this event Tim Butlin, senior manager of the examinations unit of the JFSC, spoke about:
Following this, Hamish Armstrong, chief adviser on financial crime for the JFSC, provided an overview of how and why you can enhance your due diligence measures.
Enhanced Customer Due Diligence: Refresher, by Hamish Armstrong from the JFSC
Launch of National Strategy for Combatting Financial Crime
Watch Julian Gouge speak about how he put together the National Strategy, and how businesses can use it to improve their own strategy to combat financial crime.
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Event on Combatting Financial Crime Together: Risk
Business Risk Assessments are the foundation of any Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CFT) strategy.
Earlier this year the JFSC conducted a thematic examination in regards to AML and CFT Business Risk Assessments (BRA) and strategy. At the event on 28 September 2022, Amanda gave an overview of these results.
Read the blog Combatting Financial Crime Together: Risk – summary of event held on 28 Sept 2022
Event presenting slides and film
On 14 July 2022, finance professionals were invited to a briefing on financial crime from local and international experts, to set out the progress to date from Government and the Regulator, and hear about the challenges facing the industry.
Financial Crime Strategy Industry Update
Combatting Financial Crime from JFSC
Blog posts on financial crime
Find further information on financial crime in the blog posts below:
Risky (virtual asset) business? (27 May 2022)
Protecting non-profit organisations from criminals and terrorists (28 April 2022)
Russian sanctions: can you sanction crypto? (25 March 2022)
Russian sanctions: the impact so far (15 March 2022)
Increase Your (Financial) Intelligence (17 February 2022)
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