JFSC 2024 POLITICALLY EXPOSED PERSON [PEP] examination feedback Issued 28 March 2025
28/03/2025
In November 2023, the JFSC published an industry update outlining its plan to conduct a thematic examination on how supervised persons were meeting their obligations regarding politically exposed persons (PEPs).
The examinations took place during the first half of 2024. The two main reasons for selecting this theme were:
- The island’s exposure to the higher risks of conducting business with customers who are either PEPs or who have a PEP connection, highlighted in the 2023 update to Jersey’s National Risk Assessment: Money Laundering (2023)
- The recent changes to Article 15A of the Money Laundering Order, which enables a supervised person to declassify a PEP, provided specific requirements are met
The JFSC examined a cross-section of industries, including accountants, banks, fund services businesses, investment businesses and trust company service providers.
The graph below represents the spread across these sectors:
The JFSC SAID:-
- The findings from this thematic examination indicate that supervised persons should be considering their own arrangements for PEP customers but specifically:
- The changes to the Money Laundering Order to enable the declassification of PEPs, with different timeframes depending on the type of PEP, came into force in September 2023.
- Supervised persons overall
- HAD implemented adequate policies and procedures addressing differing declassification requirements depending on the type of PEP.
- WERE performing and documenting risk assessments before declassifying PEP customers.
Read the full examination feedback.
https://www.jerseyfsc.org/media/8171/2024-politically-exposed-persons-examination-feedback.pdf
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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.