ASK MAT - IM A LENDER AND A JERSEY COMPANY THAT HAS LENT TO JERSEY CLIENTS [ONLY]. AM I A LOW-RISK SCHEDULE 2 LENDER?
09/11/2025
ASK MAT - IM A LENDER AND A JERSEY COMPANY THAT HAS LENT TO JERSEY CLIENTS [ONLY]. AM I A LOW-RISK SCHEDULE 2 LENDER?
MAT SAYS:
- Based on the JFSC guidance and recent LAW amendments, you can qualify as a low-risk Schedule 2 lender if you meet all the following criteria under the Proceeds of Crime (Low Risk Financial Services Business) (Jersey) Order 2024:
Low-Risk Exemption Criteria
- You are a Jersey resident or a Jersey company where all members and directors are Jersey residents.
- You are only registered for lending activity (i.e., no other Schedule 2 activities).
- You do not publicly advertise lending services.
- You lend your own funds (not third-party or pooled funds).
- All funds are paid to and from banks registered with the JFSC.
- You only lend to Jersey residents or Jersey companies where all members are Jersey residents. [walkersglobal.com], [linkedin.com]
Important Notes
- If you meet these conditions, you are designated as low-risk and exempt from certain AML/CFT obligations, but still in scope of Schedule 2.
- If you advertise lending services, lend to non-Jersey clients, or engage in other Schedule 2 activities, you lose the exemption and must comply fully with AML/CFT requirements.
- Lending must be “as a business” to trigger Schedule 2 obligations. Indicators include frequent loans, commercial terms, interest charged, and structured repayments. [jerseyfsc.org], [comsuregroup.com]
SOURCES
https://www.walkersglobal.com/en/Insights/2025/09/Adjusting-the-scope-of-Schedule-2
https://www.jerseyfsc.org/industry/financial-crime/schedule-2-business-lending-faqs/
https://www.comsuregroup.com/news/schedule-2-business-lending-faqs-published-on-09th-june-2023/
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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.