JFSC 2025 Thematic Examination Feedback on Suspicious Activity Reporting (SAR)

Executive Summary

• The Jersey Financial Services Commission (JFSC) conducted a thematic examination of 9 supervised firms in 2025, focusing on compliance with suspicious activity reporting obligations under the Money Laundering (Jersey) Order 2008 and the AML/CFT/CPF Handbook.

Overall outcome:

• Good level of compliance. 4 out of 9 firms received no findings.
• However, 5 firms had findings, primarily in:
• Policies and procedures
• SAR register and records
• Role and independence of the MLRO

Key message from JFSC:

• All firms received feedback.
• Firms with findings must submit a formal remediation plan with actions and timescales.

Good Practice + Common Findings

This report highlights what the JFSC expects (good practice) and what not to do (common findings) to help MLROs strengthen their firm's controls.

1. What the JFSC Expects (Good Practice)

2. What NOT to Do (Common Findings to Avoid)

3. Legal & Regulatory Reminders

• Failing to report knowledge or suspicion of ML/TF is a criminal offence (Proceeds of Crime Law & Terrorism Law).
• Employees must raise iSARs "as soon as practicable".
• MLRO must assess and file eSARs promptly.
• Strong controls required to prevent tipping-off.

4. Checklist for MLROs

Use this checklist to self-assess your firm's SAR arrangements:

Board Oversight

• Board receives regular, detailed MLRO reports on SAR timeliness and volumes.
• Board minutes document scrutiny and challenge of MLRO reporting.
• A clear feedback loop exists between MLRO and the Board.

Policies & Procedures

• Policies are up-to-date (reviewed regularly) and aligned with the current Handbook.
• Policies cover: iSAR submission, MLRO acknowledgement, disciplinary action for non-reporting, and updating FIU on additional information.
• iSAR form and templates are easily accessible to all staff.
• Tipping-off procedures are clearly documented, and staff are trained.

SAR Register & Records

• SAR register is complete and includes date suspicion arose, date of iSAR, submitter details, customer/transaction details.
• Full records maintained for all enquiries, decisions (including rationale), and supporting documents.
• Records allow quick retrieval of supporting documentation.

MLRO Role & Independence

• Up-to-date job descriptions for MLRO and DMLRO.
• Regular MLRO–DMLRO oversight meetings (if DMLRO is active).
• Conflicts of interest are recorded and mitigated.
• MLRO has adequate authority, resources, and independence.

Training

• All staff receive tailored training on identifying and reporting suspicions.
• MLRO/DMLRO receives role-specific training (iSAR handling, FIU liaison, tipping-off, production orders).

Compliance Monitoring

• Regular testing of SAR systems and controls is performed.
• Results are reported to the Board with remediation plans and tracking.

General

• Effective measures to prevent tipping-off.
• Clear escalation procedures for staff to raise iSARs without delay.
• MLRO has timely access to all relevant information.

Recommended Next Steps for MLROs

1. Review your current SAR framework against this checklist.
2. Address any gaps immediately.
3. Prepare evidence of enhancements (for potential future JFSC engagements).
4. Update Board on findings from this thematic review and your remediation actions.

This report and checklist are derived directly from the JFSC's May 2026 Examination Feedback document. MLROs should treat this as a key tool for ongoing compliance and risk mitigation.

Sources

https://www.jerseyfsc.org/media/vrtgwzqn/examination-feedback-suspicious-activity-reporting.pdf

https://www.jerseyfsc.org/industry/examinations/examination-findings-and-questionnaires/2025-suspicious-activity-reporting-examination-feedback/