JFSC 2026/27 thematic examinations – NEXT UP: CRAs & BO

24 September 2026: JFSC Advance notice of two financial-crime theme visits:-

• Customer risk assessments [CRA] starting on or before 9 October 2026 and on-site work across 2027.

• Beneficial ownership [BO] and control — on-site examinations in the second half of 2027,

What the Commission has said:

• The Jersey Financial Services Commission has published an update on its 2027 thematic examination programme.

• The next two themes both sit in financial crime:

  • Customer risk assessments [CRA] — questionnaire issued on or before 9 October 2026; on-site examinations in the first half of 2027.

  • Beneficial ownership [BO] and control — on-site examinations in the second half of 2027, with further detail on timing and scope still to come.

• The Commission’s own description is that these examinations address current or emerging regulatory and financial crime risks and will involve firms across different sectors. That is programme language, not a finding against any firm.

Customer risk assessments — the live workstream

• This is the theme with dates attached. Selected firms will receive an email questionnaire covering obligations in the Money Laundering (Jersey) Order 2008 and the AML/CFT/CPF Handbook.

• After responses are analysed, a sample of firms will be selected for on-site visits.

• Key operational dates from the notice:

  • Questionnaire emailed on or before 9 October 2026 and also published on the JFSC website.

  • Firms selected for on-site work will be notified by their supervisor in December 2026.

  • Information requests for the onsite phase will not be issued before January 2027.

  • Onsite start in H1 2027.

• The Commission says it is publishing the questions in full so that all firms can use them as a self-assessment tool, whether or not they are selected. Firms that complete the questionnaire but are not visited on-site may still have a sample of their answers verified. The notice also states the usual expectation: deal with the Commission openly, cooperatively and candidly.

• The JFSC points firms back to its 2021 feedback paper on customer risk assessments and says the observations and good-practice examples remain relevant. That is an invitation to re-read old findings, not a claim that nothing has changed in five years.

Stated rationale

• Customer risk assessments sit at the centre of acceptance decisions, the intensity of due diligence, and ongoing monitoring.

• The Commission’s stated aim is to identify trends, highlight good practice and share observations. That is the official purpose.

• The practical effect for selected firms is a documented test of whether their CRA methodology actually drives CDD and monitoring, or whether it is a form that is completed and then ignored.

Obligations that the Commission restates

• Firms must carry out identification measures and assess ML/TF/PF risks for relationships and one-off transactions; maintain policies, procedures, systems, and controls; and ensure governance and oversight.

• Systems and controls are expected to cover:

  • Obtaining enough information to assess customer risk.

  • An effective methodology that reflects associated risks.

  • Proportionate due diligence based on that risk.

  • Re-assessment on periodic review or trigger events.

  • Documented rationale and approval for changes to risk ratings.

  • Monitoring the effectiveness of controls and keeping information current.

Examination focus areas

• Governance and oversight of customer risk.

• Systems and controls supporting assessment and management.

• Customer risk assessment methodologies.

• Adequacy and accuracy of information obtained.

• Ongoing monitoring of customer risk.

• Testing and reporting on the effectiveness of methods and compliance.

Beneficial ownership and control — H2 2027

• This theme is flagged now, but the Commission is explicit that further details on timing, scope, focus areas and approach will follow. Treat this as an advance warning, not a complete examination brief.

• The stated rationale is that transparency of beneficial ownership is central to the AML/CFT/CPF framework.

• The notice cites the 2024 MONEYVAL Mutual Evaluation Report, which highlights the need for further supervisory focus on complex structures and on individuals who control through other means.

• The last JFSC examination of this topic, in 2022, focused on customers with trust structures in the ownership chain. The 2027 theme is framed more widely:

  • How firms understand beneficial ownership and control of complex structures, against revised Handbook guidance published on 31 May 2026.

  • How firms assess and document control held through other means when applying the three-tier test.

• That second bullet is the one to take seriously. “Control by other means” is where many files look tidy on paper and thin under questioning.

• The three-tier test only works if the firm can show how it looked beyond legal ownership and named office-holders.

What this is — and what it is not

• This is a supervisory thematic programme. It is not an enforcement announcement, not a finding of industry-wide failure, and not a new legal obligation. The legal baseline remains the 2008 Order and the Handbook.

• It is also not optional reading. A questionnaire issued to selected firms, with later sample verification, even for firms not visited on-site, means that answers will be treated as representations to the supervisor. Incomplete, optimistic or internally inconsistent responses will be visible.

• Boards should not assume that “we were not selected” ends the matter. The questions will be public. Feedback after the on-sites will include aggregated questionnaire data. The current CRA methodology, which will remain unchanged until an onsite letter arrives in 2027, is a choice rather than a strategy.

Practical next steps for firms

• Treat the published CRA questionnaire as a self-assessment immediately, not after 9 October.

• Re-read the 2021 CRA feedback paper against current files, not against the policy manual.

• Test whether risk ratings actually change CDD intensity, approval routes and monitoring frequency.

• Check that trigger-event re-ratings exist in practice and that rating changes have a documented rationale and approval.

• Map complex structures against the 31 May 2026 Handbook guidance on beneficial ownership and control.

• Document how “control by other means” is identified under the three-tier test, including negative findings.

• If an email arrives, meet the deadline and answer the question asked. Do not draft a brochure.

If you receive the questionnaire, the Commission’s next steps text is clear:

• Submit before the deadline; expect analysis first;

• Expect December 2026 notification if selected for onsite;

• Expect no information requests before January 2027.

Contact the Commission

• Questions about the thematic examination programme should be directed to the Examination Unit at fscseu@jerseyfsc.org.

Source

• Jersey Financial Services Commission, “Read our 2027 thematic examination programme”: https://www.jerseyfsc.org/news-and-events/read-our-2027-thematic-examination-programme/

• This bulletin restates the JFSC notice and sets out a practical reading of it. It is not legal advice, and it does not add obligations that the Commission has not published.

Comsure can assist with:

1. Questionnaire readiness,

2. CRA methodology testing,

3. File sampling, and

4. Mapping of complex ownership and control against the May 2026 Handbook text.

Contact

Mathew Beale | Chartered FCSI -

+44 (0) 1534 626830 - +44 (0) 1534 626841 - +44(0)7797 747 490

mathew@comsuregroup.com