JFSC annual supervisory risk data reports showing aggregated data for the Trust company business sector

Read here:- https://www.jerseyfsc.org/media/xzom1af4/supervisory-risk-data-tcb-sector-report-2024.pdf

The JFSC have published annual supervisory risk data reports showing aggregated data for the trust company business, investment business, banking, legal and funds sectors to:

• Provide a general overview of each sector
• Improve the understanding of money laundering and terrorist financing risks across different sectors
• Read here:- https://www.jerseyfsc.org/media/xzom1af4/supervisory-risk-data-tcb-sector-report-2024.pdf

Warning

• The JFSC remind readers that the reports are not risk assessments.

The supervisory risk report includes DATA from the businesses and individuals that the JFSC supervise

• Organisational,
• Footprint,
• Customer and
• Compliance

 The aim of publishing these reports remains to improve understanding of money laundering and terrorist financing risk within each sector and to enable comparison across sectors and activities.

The data in these reports cover 2020 - 2024 and provide a general overview of each sector, along with trends in inherent risk factors such as customers from higher-risk jurisdictions and politically exposed persons (PEPs) connections.  

EXECUTIVE SUMMARY - Trust company business sector

Jersey has a large and significant trust company business (TCB) sector,

• Directly employing over 5,000 individuals and
• With a geographical reach second only to the banking sector.

In October 2025,

• The JFSC  website listed:
• 776 persons registered to carry on TCB activity, including natural persons and participating members
• By January 2026, this figure had fallen to 759
• Jersey’s TCB sector has customers from
• 175 jurisdictions, and
• The vast majority of customers reported as residents outside Jersey.
• Sector activities,
• The sector offers a full range of trust and company activities,
• With management services reported as the activity most often provided to customers.
• The level of management services activity has stabilised at
• Approximately 67.5% of the reported activity in both 2023 and 2024,
• A decrease from the high in 2020 (75%).
• Trustee-only services –
• Over 2023 and 2024, there has been an increase in the provision of trustee-only services.

COUNTRY RISK IN 2024,

• 4.8% of TCBs reported non-Jersey customer relationships were from higher-risk jurisdictions,
• A significant decrease from 2023 (7.8%), primarily due to South Africa being removed from the FATF grey list.
• Other prominent higher-risk jurisdictions include:
• Kenya (0.9%),
• Monaco (0.9%),
• Lebanon (0.8%), and
• Russia (0.2%).  
• The proportion of customers from higher-risk jurisdictions associated with terrorist financing has decreased
• From 2.4% in 2021 to 1.5% in 2024,
• Primarily due to the continued decline in Russian customers. 

OTHER RISKS

• PEP RISK IN 2024
• The TCB sector has the highest level of PEP connections relative to the total number of reported customer relationships (14.5%),
• With the total number of PEP connections stabilising in 2024 after rising steadily over 2020 - 2023.  
• EDD RISK IN 2024
• The data continues to demonstrate that enhanced customer due diligence (CDD) is applied to customers other than those rated as higher risk.
• It has been applied to 57% of customer relationships, reflecting the sector’s conservative approach to customer onboarding. 

DATA NOTES

• An explanation has been provided to support the aggregated data presented through a combination of graphs and tables. Whilst some data quality and integrity checks are performed on receipt of the data, the JFSC relies on the accuracy and completeness of the data provided by industry.
• Data for each year of the five years is considered against:
• The most recent Appendix D2 (October 2025)
• Appendix D2 at year-end
• APPENDIX D2 MEASURES:
•  Highlights the impact of the FATF grey listing, as, across sectors, exposure peaked in 2023, when both South Africa and the United Arab Emirates were listed on Appendix D2.

DEEP DIVE INTO THE DATA – EXTRACTS FROM THE REPORT

Customer Residency

Non-Jersey Customers or Beneficial Owners (2024 Top 10 Jurisdictions):

• Top 10 Jurisdictions Share: 71.9% of reported customer relationships (down from 72.1% in 2023)
• UK Share of Non-Jersey Relationships: 44.8% (slight decrease from prior years)

Higher Risk Jurisdictions (Money Laundering - Static, FATF Black/Grey List or 3+ Sources in Appendix D2)

• Individual Customers or Beneficial Owners Resident in Higher Risk Jurisdictions (Top 5, 2020-2024 Trends):

• Overall Exposure: 4.8% in 2024 (down from 6% in 2021)
• Jurisdictions with No Connections: 22 out of 65 higher-risk jurisdictions
• Jurisdictions with Minimal Connections (<0.05%): 33 out of 65
• Russian Federation Exposure: 0.2% in 2024 (decline due to geopolitical pressures)

Higher Risk Jurisdictions (Money Laundering - Dynamic, FATF Grey List Changes)

• Exposure Peak: 2023 (due to South Africa and the UAE on the grey list)
• Exposure Reduction from 2023 Peak: 54% (after removals of South Africa and UAE)
• Notable Grey List Additions/Removals (2020-2025):

Higher Risk Jurisdictions (Terrorist Financing, Government of Jersey List)

• Individual Customers or Beneficial Owners Resident in Higher Risk Jurisdictions (2020-2024 Trends): 1.5% in 2024 (down from 2.4% in 2021)
• Reduction Primarily Due To: Fewer relationships with Russia and Kenya.

Politically Exposed Persons (PEPs)

• Total PEP Connections: 9,500 in 2024 (down from 9,700 in 2023)
• PEP Exposure: 14.5% of all customers in 2024
• PEP Exposure by Customer Type (2024): Non-Jersey companies (19.3%), Jersey companies (18.6%)
• PEPs Declassified: 351 in 2024 (up from 0 before 2023 MLO update)

Politically Exposed Persons (Jurisdictions)

• Connections to PEPs from Appendix D2 Source 7 Jurisdictions (Corruption Perception Index): Steady decrease from 2020 to 2023, stable in 2024

Customer Risk

• Customers Rated as Higher Risk: 29% in 2024 (down from 31% in 2023)
• Higher Risk by Customer Type (2024): Non-Jersey companies (48.8%), Jersey companies (34.3%)
• Enhanced CDD Applied: 57% of customer relationships in 2024

High Net Worth Customers and Use of Tax Disclosure Facilities

• Customers Registered for Foreign Tax Disclosure Facility (2020-2024 Trends): 32 in 2024 (down from 1,105 in 2020)
• High Net Worth Customers (AUM £25m+): 20% increase in 2024

Trust Company Business Services Provided

• Services by Customer Type (2024):

• Management Services: 67.6% of reported activity in 2024 (down from 75% in 2020)
• Limited Services: 16.2% of TCB customers in 2024
• Rise in Trustee-Only Services: Observed over 2020-2024

Trust Company Business Sector Employees

• Employee Trends (2019-2024):

• Compliance and Risk as % of Total Employees: 10.5% in 2024 (average 10% over 2020-2024)
• Compliance/Risk Employees Outside Jersey: 8% in 2024 (up from 3% in 2020)
• Compliance and Risk Vacancies: 4% in 2024 (down from 8% in 2022)

Reliance on Obliged Persons and Money Laundering Order Exemptions

SOURCES

• https://www.jerseyfsc.org/media/xzom1af4/supervisory-risk-data-tcb-sector-report-2024.pdf
• https://www.jerseyfsc.org/industry/risk/supervisory-risk-data-collection-exercise/sector-based-aggregated-data-2020-2024/
• https://www.jerseyfsc.org/news-and-events/read-The JFSC -latest-aggregated-supervisory-risk-data/