JFSC add five more quick wins (12 in total) for financial crime compliance

THE JFSC publish what it says are  quick wins for financial crime compliance:-

• IN JANUARY 2025, the JFSC published seven quick wins for financial crime compliance, which outlined common areas of non-compliance that should be relatively easy to address.
• NOW IN NOVEMBER 2025, the JFSC has identified five new quick wins, as well as highlighting five areas of non-compliance that the JFSC continue to see.

By reviewing and addressing these TWELVE 2025  QUICK WINS, you can enhance the effectiveness of your systems and controls to prevent money laundering, terrorist financing, and proliferation financing.

Please see below the TWELVE 2025  QUICK WINS from JFSC January and November 2025 updates 😊

January 2025 - The JFSC’s “Seven Quick Wins for Financial Crime Compliance” (published January 2025)

1. Suspicious Activity Reports (SARs) – Date Information

• Issue: SARs often lack the date when the matter first came to the employee’s attention.
• Action: Make this date a mandatory field in SAR forms and registers.

2. SARs – Reporter Information

• Issue: SAR registers sometimes omit the name and capacity (e.g., MLRO or Deputy MLRO) of the person who filed the SAR externally.
• Action: Ensure SAR registers record both the name and capacity of the reporter.

3. Inadequate Screening Records

• Issue: Firms conduct adverse media, PEP, and sanctions searches but fail to document outcomes.
• Action: Annotate search results to confirm:

• No hits identified
• Hits reviewed and confirmed as false positives
• Rationale for discounting hits

4. Inadequate Screening Policies and Procedures

• Issue: Policies for adverse media, PEP, and sanctions screening are unclear or incomplete.
• Action: Maintain clear procedures detailing when and how searches should be conducted.

5. Politically Exposed Persons (PEPs) – Incorrect Definitions

• Issue: Definitions of domestic/foreign PEPs, prominent persons, family members, and close associates do not match the Money Laundering (Jersey) Order 2008.
• Action: Regularly review and align definitions with Article 15A of the Order.

6. Conflicts of Interest Registers

• Issue: Registers are not kept up to date.
• Action: Review and update regularly to ensure completeness.

7. Documentation of Open-Source Searches

• Issue: Firms fail to keep adequate records of open-source checks.
• Action: Retain evidence of searches and outcomes for audit and regulatory review.

NOVEMBER 2025

NOW IN NOVEMBER, the JFSC has identified five new quick wins, as well as highlighting five areas of non-compliance that the JFSC continue to see.

1. Risk appetite 

1. 1. Area of non-compliance
      • The JFSC see vague risk appetite statements without clearly defined parameters. The JFSC also see examples of unrealistic risk appetite statements, for example, a zero or low-risk appetite where there is a high proportion of high-risk customers.  

1. 2. Solution
      • Check that your risk appetite statement is sufficiently clear so that the board can articulate it, and employees can understand it when deciding whether to accept new business.
      • Make sure your book of business accurately reflects your risk appetite. If it doesn’t, this indicates your risk appetite requires review. 

2. Proliferation financing 

1. 1. Area of non-compliance
      • The JFSC often see business risk assessments without any assessment of proliferation financing risks and mitigants.   

1. 2. Solution
      • Ensure that your business risk assessment identifies proliferation financing risks and the systems and controls implemented to manage those risks.
      • Confirm that the cumulative effect of these risks has been considered alongside other risks identified. 

3. Customer risk assessments  

1. 1. Area of non-compliance
      • The JFSC see instances of customer risk ratings being downgraded in the absence of a documented process, independent approval or a well-articulated rationale. 

1. 2. Solution
      • Please make sure you have a straightforward procedure setting out the circumstances in which a risk rating can be amended and who is authorised to do so.
      • Document why it is appropriate in each case?  

4. Policies and procedures 

1. 1. Area of non-compliance
      • The JFSC often see policies and procedures which have not been reviewed at appropriate intervals or kept up to date.  

1. 2. Solution
      • Establish a review cycle for all policies and procedures so that you can demonstrate they are being maintained.
      • Check if you have a process for updating these policies and procedures when trigger events occur. You should also be able to document the date of any review, even if no changes are made. 

5. Certification 

1. 1. Area of non-compliance
      • In the JFSC reviews of customer files, the JFSC frequently find that documents have not been certified in accordance with policies and procedures.  

1. 2. Solution
      • Ensure that your employees understand and follow your requirements for suitable certification, including what information should be captured, as well as when and how to verify a certifier’s details. 

AREAS OF NON-COMPLIANCE THAT THE JFSC CONTINUE TO SEE.

Other issues highlighted in the JFSC's previous quick wins that the JFSC still identify in the JFSC exams in 2025: 

6. Suspicious activity reports – date information 

1. For internal suspicious activity reports (SARs), many entities record the date of suspicion “BUT NOT” the date the information or matter came to the employee’s attention, which might be different. [The AML/CFT/CPF Codes of Practice require this]
2. Ensure this date is captured in your SAR forms. This allows the board and senior management to assess the timeliness of internal suspicious activity reports. 

7. SAR registers – reporter information  

1. The JFSC also see SAR registers which do not record the role of the individual making an external SAR, such as whether the person is the MLRO or Deputy MLRO, as required by the AML/CFT/CPF Codes of Practice.
2. Check your SAR register records this information. 

8. Screening  

1. Maintain clear policies and procedures for conducting adverse media and open-source searches, including sanctions searches.  

9. Screening records

1. Ensure search results are documented, including the rationale for discounting hits.  

10. Exemptions from customer due diligence requirements  

1. Ensure exemptions are only used in appropriate circumstances and document the rationale for application. 

These essential components for full compliance with the AML/CFT/CPF regulatory requirements are sometimes all that is missing from otherwise comprehensive and robust systems and controls.

THE JFSC SAYS:

• You should check these areas to use your financial crime prevention framework. 

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