JFSC D2 UPDATE – Grey-Listed Countries Require 6 days of MANDATORY EDD – Then It's Up to You

Countries & Territories in AML/CFT/CPF Handbook Appendices Updated in Response to FATF Statements – 19 June 2026 | Effective Immediately

FATF Plenary Outcomes & Key Changes (17–19 June 2026)

• The FATF issued updated statements on 19 June 2026. Key changes to the grey list (increased monitoring); :
• Bosnia and Herzegovina and Iraq added
• Algeria and Namibia removed.
• FATF did not change
• DPRK and Iran remain subject to countermeasures.
• Myanmar remains on enhanced due diligence (potential countermeasures if insufficient progress by October 2026).
• Note: FATF encourages a risk-based approach for grey list jurisdictions; countermeasures apply only to specified blocklist cases.

JFSC AML/CFT/CPF Handbook Update (19 June 2026)

• In response to the FATF statements, the JFSC updated Appendix D1 and Appendix D2. Source 2 of Appendix D2:
• Bosnia and Herzegovina and Iraq added; Algeria and Namibia removed.
• Countries/territories listed under Sources 1 and 2 of Appendix D2 must be treated as not compliant with FATF Recommendations for Article 17A of the Money Laundering Order.

Important Transitional Note:

• Jersey MLO Amendments & Handbook Updates (31 May – 30 June 2026)
• The updated AML/CFT/CPF Handbook became effective on 31 May 2026.
• However, key amendments under the Money Laundering (Jersey) Amendment Order 2026 (made 17 April 2026) come into force on 30 June 2026.

Why grey listing after 30 June is not such a regulatory burden — but requires more oversight in the next 6 days:

• Under the current rules (until 30 June),
• Countries on the FATF grey list (Source 2 of Appendix D2) are treated as not compliant with FATF Recommendations for Article 17A of the Money Laundering Order.
• This typically restricts the ability to place reliance on obliged persons in those jurisdictions and can trigger enhanced measures or automatic heightened scrutiny.
• From 30 June 2026,
• The shift to a more explicitly risk-based framework gives supervised persons greater flexibility to apply nuanced, documented risk-based judgements rather than automatic restrictions based solely on FATF grey list status.

Therefore:

• For the next 6 days (today is 24 June - until 30 June 2026):
• The stricter pre-amendment rules still fully apply. Newly grey-listed jurisdictions (Bosnia & Herzegovina and Iraq added 19 June) require immediate heightened oversight.
• Supervised persons should prioritise urgent reviews of customer relationships, reliance arrangements, and policies involving these jurisdictions during this short transitional window, before the more flexible risk-based regime takes effect.
• After 30 June:
• Grey listing is less of an automatic regulatory burden. Firms can more readily document risk-based decisions and apply proportionate measures.

Action:

• Document your risk assessments and any enhanced monitoring for affected jurisdictions now, ahead of the 30 June transition.

What This Means – Immediate Effect (19 June 2026 Updates)

• Countries/territories listed under Sources 1 and 2 of Appendix D2 must be treated as not compliant with FATF Recommendations for Article 17A of the Money Laundering Order.

Next Steps – Action Required by Supervised Persons

1. Review policies, procedures & existing customer relationships for impact of the 19 June FATF/JFSC updates.
2. Prioritise heightened oversight of relationships involving newly grey-listed jurisdictions (Bosnia & Herzegovina, Iraq) in the next 6 days.
3. Exercise particular care when placing reliance on obliged persons in affected jurisdictions.
4. Discuss concerns with your JFSC supervisor and prepare for the risk-based regime effective 30 June 2026.

Key Resources (copy-paste ready)

• JFSC 19 June 2026 Update: https://www.jerseyfsc.org/news-and-events/countries-and-territories-in-amlcftcpf-handbook-appendices-updated-19-june-2026/
• FATF Grey List – 19 June 2026: https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html
• FATF Black List – 19 June 2026: https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/call-for-action-june-2026.html
• Money Laundering (Jersey) Amendment Order 2026: https://www.jerseylaw.je/laws/current/Pages/08.780.30.aspx (or search "Money Laundering (Jersey) Amendment Order 2026" on jerseylaw.je)
• JFSC AML/CFT/CPF Handbook (effective 31 May 2026): https://www.jerseyfsc.org/industry/financial-crime/amlcftcpf-handbooks/amlcftcpf-handbook/

Disclaimer: This bulletin summarises key developments. Always refer to the full official JFSC Handbook, Amendments Log, Money Laundering Order, and FATF statements for authoritative guidance. This is not legal advice.