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Government unveils updates to Private Fund Regime and Sound Business Practice Policy

23 July 2025

The first two initiatives which will help to protect and grow Jersey’s financial services sector have been announced. 

The Jersey Private Fund, JPF, regime has been modernised to be better aligned with the needs of international professional investors. 

Proposals to simplify the Sound Business Practice Policy, SBPP, have been published which, once approved, will streamline its application whilst a more comprehensive review of this framework is undertaken. 

Both initiatives are part of the Competitiveness Programme and were unveiled at its launch event. 

Jersey Private Fund 

The Minister with responsibility for Financial Services, Deputy Ian Gorst, has signed a Ministerial Order to update the JPF. 

Effective from 6 August 2025, the revised JPF Guide and a new statutory instrument, the Collective Investment Funds (Jersey Private Funds) Order, will come into force. 

These changes will: 

  • remove the 50-offer / investor cap; 
  • expand the definition of professional investor; 
  • permit the listing of interests in JPFs with the Jersey Financial Services Commission's consent; and 
  • introduce a 24-hour authorisation process for JPF applications submitted by registered Designated Service Providers.

Jill Britton, Director General of the JFSC, said: “The updated JPF regime is a significant step, keeping Jersey’s fund offering evolving with the needs of industry. JPFs continue to be a regulated product that investors can have confidence in – these changes streamline the regime and, together with our commitment to faster authorisation, we are underscoring our commitment to excellent service.” 

Joe Moynihan, CEO, Jersey Finance, said: "Since its launch in 2017, the JPF has become Jersey’s fastest-growing fund category, particularly well-suited to private equity, venture capital and real asset strategies. As private capital continues to evolve globally, these updates will further increase Jersey’s appeal to managers and professional investors seeking flexible and well-regulated fund solutions.” 

Deputy Gorst said: “These revisions follow industry engagement and reflect a broader global movement toward bespoke, efficient private fund vehicles for professional investors. They provide certainty for fund promoters and reinforce Jersey’s appeal as a jurisdiction of choice for private capital.” 

Sound Business Practice Policy 

The SBPP, jointly developed by Government of Jersey and the JFSC, identifies ‘sensitive activities’ which require additional information or scrutiny before the JFSC consents to them. The Codes of Practice for investment business, funds service business, certified funds and trust and company businesses all require registered persons to have due regard to the SBPP. 

The SBPP has served Jersey well in understanding and managing risk, but updates are required to ensure it remains fit for modern-day business. 

The proposed amendments simplify its scope of application, reducing potential business frictions and delays. The “Repeal of the Control of Borrowing Framework”, recently published by the Government of Jersey, includes a review of the SBBP framework with a view to establish a more flexible risk-based approach in the medium-term. 

Jill Britton said: “This is about modernising regulation while taking a progressive stance against financial crime. Refining the SBPP removes unnecessary complexity and enables firms to focus on what matters, identifying and managing real risk. It’s a shift toward more intelligent regulation, where the emphasis is on outcomes and accountability, not just process”. 

Joe Moynihan added: “We welcome the simplification of the SBPP, which should have a material impact on Jersey’s competitiveness as an IFC that is very much open for high quality business. These changes, which are in response to industry feedback, are another good example of our agility as an IFC and the positive collaborative relationship there is between industry, the Government of Jersey and the JFSC.” 

Deputy Gorst said: “This change will enable businesses to do what they already do well: determine the risk of their activity and to act accordingly. Jersey has a mature and sophisticated financial services sector, and this change acknowledges that. The simplification of the SBPP does not reduce Jersey’s commitment to combatting financial crime but rather acknowledges that the industry understand risk and allows them to take greater responsibility for managing it.” 

Competitiveness Programme 

The Competitiveness Progamme has brought together government, the regulator and industry with the goal of protecting Jersey’s current economic strength, while unlocking new pathways for growth over the next ten years. 

The programme is organised around four strategic workstreams, with each designed to address a key dimension of Jersey’s competitiveness: 

  • International Tax Strategy – focusing on creating a tax framework that keeps Jersey competitive and compliant in a fast-changing global landscape. 
  • Business and Regulatory Environment – delivering practical, quick-impact improvements to ease of doing business and regulatory efficiency, while also shaping longer-term reforms. 
  • External Growth Strategy – comparing Jersey’s strengths and weaknesses, opportunities and threats, against global trends and competing jurisdictions, this stream will offer data-driven insights and targeted investment opportunities to fuel long-term, realisable international growth. 
  • Future Competitiveness and Regulation – bringing together a high-level panel of global experts to synthesise and prioritise the findings from across the workstreams, producing an independent report for Ministers. 

At the end of this process of research and reflection, the Government will publish a final report and action plan in 2026 that will shape Jersey’s strategy into the next decade.

These efforts align closely with other major initiatives such as Jersey Finance’s Vision2050 and the JFSC’s registry and strategic reviews, which ensures that workstreams are not happening in silos, but as part of a broader, coordinated vision. 

For more on the Financial Services Competitiveness Programme, please see: Financial services competitiveness programme​​.

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