JFSC feedback on the Compliance function: Key Person regime green paper.
14/04/2025
On 11 October 2024, the JFSC issued a green paper on the Compliance function: Key Persons Regime in response to the industry’s challenges in resourcing Key Person roles.
This green paper explored three options:
- Option 1: status quo – retain employment and residency requirements for Key Persons with enhancements
- Option 2: retain the employment connection of Key Persons and remove the Jersey residency requirement
- Option 3: retain the Jersey residency requirement for Key Persons and remove the Key Person employment requirement
The JFSC sought feedback on these options, including their impact on recruitment, industry benefits, FATF compliance, and associated risks. The JFSC also considered the role of RegTech.
Feedback received
- The consultation closed on December 6, 2024, with 47 responses. 55% of respondents who indicated a preference selected option 1.
- The feedback suggested no need for significant reforms, as resourcing pressures have subsided. The JFSC will focus on agreed changes to improve the business environment.
Next steps: Key Persons priority enhancements
The JFSC will explore several priority enhancements:
- Outsourcing policy: review its interaction with the Key Persons regime and the compliance function in general
- Derogation and variance guidance: guide time-limited derogations and variance applications
- Key Person liability: engage with the industry on key person liability in enforcement actions
- RegTech guidance: share feedback and review existing guidance to support adoption
The JFSC states:-
- As part of the Government of Jersey's financial services competitiveness programme, the JFSC will collaborate with the government and other key stakeholders to consider any strategic or long-term solutions to drive positive outcomes, increase the ease of doing business, and enhance cooperation.
Read the JFSC Feedback on the Compliance function: Key Persons regime green paper here.
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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.