2024 feedback from the 2023 JFSC examination of reliance on obliged persons
18/04/2024
During the first quarter of 2023, the JFSC assessed how supervised persons had complied with their obligations relating to reliance on obliged person.
This 2024 feedback paper aims to publish an anonymised summary of the key findings the JFSC identified during the thematic examination and set out relevant good practices for the benefit of all supervised persons.
BACKGROUND
In strictly limited cases, supervised persons are permitted to rely on measures applied by a third party to meet some of their customer due diligence (CDD) and enhanced CDD measures obligations.
Reliance on third-party measures must always be subject to six conditions in Article 16 of the Money Laundering (Jersey) Order 2008. Where the requirements of Article 16 are not met, supervised persons’ CDD measures may be ineffective, potentially exposing them to a heightened risk of financial crime.
In addition to the requirements in Article 16, the Handbook includes further requirements relating to reliance in the form of AML/CFT/CPF Codes of Practice.
THE REPORT
A detailed overview of the examination findings is set out in section 6 OF THE REPORT READ HERE
- https://www.jerseyfsc.org/media/7494/q4-2023-reliance-thematic-feedback-paper.pdf
- https://www.jerseyfsc.org/industry/examinations/examination-findings-and-questionnaires/feedback-from-the JFSC-examination-of-supervised-persons-reliance-on-obliged-persons/
Supervised persons should consider the findings in this report and, where relevant, implement changes to align with good practice.
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.