JFSC recommends seven quick wins for financial crime compliance

The JFSC has published, ahead of its 2025 financial crime examination feedback, seven common areas of non-compliance that should be relatively easy to address.

The JFSC says:-

• These SEVEN areas often involve measures and controls that have been implemented but are missing essential components.
• By reviewing and addressing these seven areas, you can enhance the effectiveness of your systems and controls to prevent money laundering, terrorist financing, and proliferation financing.

The SEVEN QUICK WINS are as follows:-

1. Suspicious activity report - date information

1. JFSC Area of non-compliance

1. 1. 1. When submitting suspicious activity reports (SARs), the employee must record the date the information or matter came to the employee’s attention.
      2. The JFSC says it sees examples of SARs without this required date recorded.
   2. JFSC Solution

1. 1. 1. Ensure this data is captured by making it a required field in your internal SAR forms and SAR register.

2. Suspicious activity report - reporter information

1. JFSC Area of non-compliance

1. 1. 1. In your SAR register, you need to record the capacity in which an individual has externalised an SAR, e.g., as a money laundering reporting officer or deputy money laundering reporting officer.
      2. The JFSC sees examples of SAR registers without a record of the individual who filed the SAR.
   2. JFSC Solution

1. 1. 1. Check your SAR register records, the name of the individual making an external SAR and the capacity in which they do so.

3. Inadequate screening records

1. JFSC Area of non-compliance

1. 1. 1. Keep adequate records of adverse media and open-source search results, including politically exposed persons (PEP) and sanctions searches.
      2. The JFSC sees many examples of searches that were conducted but the entity did not document the outcome.
   2. JFSC Solution

1. 1. 1. You can demonstrate your screening is effective by annotating search results to confirm:-

1. That no hits were identified
2. That potential hits had been reviewed and confirmed as false positives
3. The rationale for discounting hits

4. Inadequate screening policies and procedures

1. JFSC Area of non-compliance

1. 1. 1. Maintain adequate policies and procedures for adverse media and open-source searches, including searches for politically exposed persons (PEP) and sanctions.
   2. JFSC Solution

1. 1. 1. Clear policies and procedures assist employees in knowing when and how to conduct adverse media and open-source searches, increasing the likelihood that your screening is effective.

5. Politically Exposed Persons (PEPs) - incorrect definition

1. JFSC Area of non-compliance

1. 1. 1. The definitions of domestic and foreign PEPs, prominent persons, prominent public functions, immediate family members, and close associates need to be correct.
      2. The JFSC sees examples of policies and procedures definitions of PEPs that do not reflect those in the Money Laundering (Jersey) Order 2008.
   2. JFSC Solution

1. 1. 1. Periodically check that your PEP-related definitions align with those in Article 15A.

6. Exemptions from customer due diligence requirements

1. JFSC Area of non-compliance

1. 1. 1. Exemptions can only be applied in certain circumstances.
   2. JFSC Solution

1. 1. 1. Before using an exemption under Articles 17 or 18 of the Money Laundering (Jersey) Order 2008, you should ensure that none of the circumstances in Article 17A applies.
      2. It is a requirement to document the rationale for applying for the exemption.

7. Conflicts of interest not recorded

1. JFSC Area of non-compliance

1. 1. 1. Conflicts of interest registers need to be kept up to date. We sometimes see incomplete registers.
   2. JFSC Solution

1. 1. 1. Periodically review your conflicts and ensure your registers are current, including mitigating measures.
      2. Recording a potential conflict on a register does not mitigate the risk.

Source

• https://www.jerseyfsc.org/news-and-events/seven-quick-wins-for-financial-crime-compliance/
• https://www.linkedin.com/posts/jersey-financial-services-commission_seven-quick-wins-for-financial-crime-compliance-activity-7287099989976076289-aD7X/?utm_source=share&utm_medium=member_ios