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JFSC Feedback from ITS compliance monitoring thematic examination

18/06/2025

The JFSC have published feedback from its 2024 compliance monitoring (CM) thematic examination. 

The JFSC says the risk of poor or ineffective CM PROGRAMMES/PLANS/PROCESS (CMPs) is:-

  • When compliance monitoring is ineffective, weaknesses in a firm’s control environment may be missed or overlooked, and the board may not accurately understand the level of risk present in the business.
  • This increases the risk of non-compliance with legal and regulatory obligations and may result in a conduct risk crystallising or an increased risk that the company may be involved in facilitating financial crime. 

The examination evaluated adherence to

  • PRINCIPLE 3 OF THE SECTOR-SPECIFIC CODES OF PRACTICE and
  • SECTION 2 OF THE AML/CFT/CPF HANDBOOK.

Specifically, the JFSC assessed how firms: 

  • Tested compliance with
    • Internal policies,
    • Procedures, and
    • Applicable legal and
    • Regulatory requirements 
  • Verified the effectiveness and implementation of systems and controls 
  • Took timely and appropriate action to address identified deficiencies 

Key findings 

GOOD

Overall, the thematic examination showed

  • Good compliance with the obligations relating to compliance monitoring, with no key trends identified.
  • Consequently, firms were seen monitoring, managing, and mitigating their risks effectively.  

BAD

Areas where the JFSC identified the most findings were about internal systems and controls, specifically: 

  • Ineffective testing 
  • Inadequate policies and procedures 
  • Inadequate and/or inaccurate records 

Read the full examination feedback paper.

 

JERSEY

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