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Home News A Jersey bank fails to file a SAR on a suspicion related to the proliferation of WMD.
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A Jersey bank fails to file a SAR on a suspicion related to the proliferation of WMD.

04/05/2025

It has been reported that:-

  • A Jersey bank failed to file a SAR on a suspicion related to the proliferation of WMD and
  • An investigation into breaches of the AML/CFT/CPF legislation by the obliged entity is still ongoing

The Jersey government's 2025 NRA on Proliferation Financing has highlighted the following case:-

  • In 2023, the authorities identified a case of potential failure by an obliged entity to file a SAR to the FIUJ concerning suspicion of money laundering stemming from the proliferation of WMD (although not directly associated with the relevant Iran or DPRK UNSCRS).
  • The source of wealth of a non-resident with an account in Jersey may have resulted from family money associated with illicit proliferation activity.
  • The individual was a Politically Exposed Person due to his relations with an individual widely believed to be a central participant in the black-market trade of nuclear technology.
  • The natural person with a Jersey account
    • Had no fixed income,
    • But operated funds received from the family, some of which were used in an attempt to purchase property.
  • The bank failed to identify
    • The family connection and ties to the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) sanctioned individuals.
  • The natural person's accounts were closed in Jersey in 2017
  • The case was initiated in 2023
    • Due to a request from a foreign Financial Intelligence Unit,
  • Only upon receiving a Proceeds of Crime Notice from the FIUJ did the bank file a SAR.
  • The investigation into breaches of the AML/CFT/CPF legislation by the obliged entity is still ongoing

Sourced Case Study 2:

https://www.gov.je/SiteCollectionDocuments/Industry%20and%20finance/PF%20NRA%20Monday%2028%20April.pdf

 

JERSEY YOUTUBE-IMAGE SAR/STR

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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.  

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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.