JFSC Money laundering and terrorist financing risk data 2019 - 2023 analysis - TRUST COMPANY BUSINESS

In December 2024, the JFSC published some Money laundering and terrorist financing risk data [2019 – 2023], for the following sectors for the first time.

1. BANKING
2. TRUST COMPANY BUSINESS - [SEE BELOW]
3. LEGAL and
4. INVESTMENT BUSINESS,  

https://www.jerseyfsc.org/industry/risk/supervisory-risk-data-collection-exercise/sector-based-aggregated-data/#Sector-based-aggregated-data

The data in the reports covers 2019 - 2023 and provides.

1. A general overview of each sector along with trends on inherent risk factors such as customers from higher risk jurisdictions and politically exposed persons (PEP) connections. 
2. An explanation has been provided to support the aggregated data presented through a combination of graphs and tables.

KEY AIMS AND OBJECTIVES

1. The aim of publishing these reports is to improve the understanding of money laundering and terrorist financing risk within each sector and enable a comparison across different sectors and activities.
2. Key risk indicators are included for each sector to provide useful benchmarking for supervised persons looking to assess their own money laundering and terrorist financing risks.
3. The JFSC will be engaging with industry through trade bodies and associations during Q1 2025 to gather feedback and inform future publications.

WARNINGS

1. The reports are not risk assessments.
2. Whilst some data quality and integrity checks are performed on receipt of the data, the JFSC rely on the accuracy and completeness of data provided by industry.

TRUST COMPANY BUSINESS SECTOR

1. Jersey has a large and significant trust company business (TCB) sector directly employing nearly 5,000 individuals and with a geographical reach that is second only to the banking sector.
2. In December 2024, the JFSC website listed:
   • 776 persons registered to carry on TCB activity, including natural persons and participating members. 
3. The data demonstrates the international nature of Jersey’s TCB sector with customers reported from
   • 171 different jurisdictions and most customers reported as being resident outside Jersey.
4. In 2023, 7.8% of TCB reported non-Jersey customer relationships are from higher risk jurisdictions with
   • South Africa (3.4%).
   • Kenya (1.0%),
   • Monaco (0.9%),
   • Lebanon (0.9%), and
   • Russia (0.3%).  
5. Due primarily to a reduction in Russian customers the proportion of customers from TERRORIST FINANCING HIGHER RISK JURISDICTIONS has
   • decreased from 2.4% in 2021 to 1.6% in 2023
6. Based on 2023 data, the TCB sector has the highest level of PEP connections when considered against the total number of reported customer relationships
   • PEP connections = 14.7% - with the total number of PEP connections steadily increasing throughout the reporting period.  
7. The data demonstrates that ENHANCED CUSTOMER DUE DILIGENCE (ECDD) has been applied for
   • 60% of customer relationships reflecting the sector’s conservative approach to onboarding new customers. 
8. The sector offers a full range of trust and company activities with management services being the activity reported as most often provided to customers.
   • Whilst management services activity represents 67.5% of the reported activity in 2023 this is a decrease from the high in 2020 (75%).
9. Over the same period there has been a rise in the provision of trustee-only service.  

Read the JFSC data report for the trust company business sector. https://www.jerseyfsc.org/media/7982/sector-data-tcb.pdf

ALL SECTORS https://www.jerseyfsc.org/industry/risk/supervisory-risk-data-collection-exercise/sector-based-aggregated-data/#Sector-based-aggregated-data