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Is the MLCO Role Dead in Jersey? Or Just Rising from the Ashes? 🔥

05/02/2026

Jersey's latest consultation paper on the Money Laundering Compliance Officer (MLCO) role has dropped a bombshell:

  • Proposals to decouple responsibility from day-to-day functions,
  • Introduce risk-based exemptions for smaller firms, and
  • Even allow corporate entities to step in as MLCOs.

Is this

  • The death knell for the traditional MLCO, buried under staffing shortages and high turnover (average MLRO tenure: just 14 months)?

Or is it

  • A bold evolution, freeing up talent pools and boosting competitiveness while staying FATF-compliant?

On one hand, it's provocative:

  • No more mandatory individual MLCOs for low-risk outfits? Delegating ops while boards hold the fort?

This could slash costs and open doors for innovative outsourcing but at what price?

  • Diffusion of accountability?
  • Conflicts in corporate providers?

Jersey's aiming for flexibility, but critics might scream

  • "Dilution of defenses against financial crime!"

Yet, dig deeper: This isn't extinction; it's adaptation.

  • Decoupling lets experienced pros join boards without the "all-or-nothing" liability trap.
  • Risk-based approaches mirror the UK and peers, easing burdens on DNFBPs like lawyers and accountants. And corporate MLCOs?
  • With safeguards like named individuals and JFSC oversight, it could widen the talent net without weakening the fight against ML/TF/PF.

Jersey's message:

  • Ultimate responsibility stays with the board. But is this rebirth or a risky gamble? In a world of escalating threats, does "less prescriptive" mean "more vulnerable"?

What say you, compliance warriors?

  • Death of the MLCO... or its phoenix moment?

Sources

Don't miss the consultation deadline: March 13, 2026.

#AML #Compliance #JerseyFinance #FinancialCrime #FATF #RegulatoryEvolution

JERSEY

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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.