JFSC 3 tier UBO guidance diagram updated – watch out for 10%-25%-or?%
25/08/2021
As of August 2021 [20th], the JFSC has updated our beneficial ownership guidance. The update includes the following updated 3 tier UBO guidance diagram:
Warning - 10% or 25% or ?%
- The JFSC say it applies the FATF standards in respect of beneficial ownership and control. To this end, a general threshold of 10% or more upon incorporation and 25% or more upon a change of beneficial ownership and control may be applied by corporate and legal entities registered in Jersey. However it is important to be aware that this is by no means a set threshold.
- A case by case risk assessment is required. The determination to be made must be in line with the AML Handbook. Therefore, the threshold will depend on the risk assessment conducted.
- The risk assessment conducted must be on the relationship as a whole. For example, upon a change of beneficial ownership, where a regulated service provider views a 20% beneficial owner is high risk, the regulated service provider should consider registering the beneficial owner on the central register even though its interest is less than the 25% threshold. This is in line with the regulated service provider’s role as a first line of defence in respect of the prevention and detection of money laundering and the financing of terrorism.
- Regulated service providers must ensure that any concerns relating to beneficial owners or business activity are highlighted to us in myRegistry upon incorporation or change (we refer to the Sound Business Practice Policy - jerseyfsc.org/industry/guidance-and-policy/sound-business-practice-policy/).
Aug 2021 update:
- https://www.jerseyfsc.org/industry/guidance-and-policy/beneficial-ownership-and-controller-guidance/
- https://www.jerseyfsc.org/media/4833/gn-beneficial-ownership-and-control-guidance.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.