JFSC webinar on Proposed Enhancements to the AML/CFT/CPF Handbook - Monday 16 June @ 14.30

The JFSC is hosting an AML/CFT/CPF Handbook update webinar on Monday, June 16, 2025, from 2:30 to 3:30 p.m.

The JFSC says the webinar aims to offer a guide through the proposed enhancements and answer any questions about the Handbook proposals.

You may like to sign up to hear what they say (CPD 😊). Sign up to attend here

• https://www.eventbrite.co.uk/e/webinar-consultation-on-enhancements-to-our-amlcftcpf-handbook-tickets-1410481711769?aff=oddtdtcreator

 Also, these are some observational notes on the consultation below, along with an outline of the consultation

OBSERVATION NOTE ON JFSC CONSULTATION ON PROPOSED ENHANCEMENTS TO THE AML/CFT/CPF HANDBOOK

The JFSC Consultation on proposed enhancements to the AML/CFT/CPF Handbook is out:- READ IT HERE –

• https://www.jerseyfsc.org/news-and-events/consultation-on-enhancements-to-our-amlcftcpf-handbook-published/
• https://www.jerseyfsc.org/media/rbynfdur/consultation-on-proposed-enhancements-to-the-aml-cft-cpf-handbook.pdf

SUMMARY

1. The Jersey Financial Services Commission (JFSC) issued a consultation paper (No. 42025) on 12 June 2025, seeking feedback on proposed enhancements to the Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Countering Proliferation Financing (CPF) Handbook.
2. The consultation, open until 4 September 2025, aims to address MONEYVAL Recommended Actions and improve the Handbook’s clarity and usability.
3. The proposed changes affect supervised persons, including Financial Institutions (FIs), Designated Non-Financial Businesses and Professions (DNFBPs), Virtual Asset Service Providers (VASPs), and Prescribed Non-Profit Organisations (NPOs).
4. The revised Handbook will take effect on 1 January 2026, and feedback will be published by early November 2025.
5. The JFSC’s proposed enhancements to the AML/CFT/CPF Handbook are a proactive response to MONEYVAL’s Recommended Actions and an opportunity to improve compliance clarity and usability for Jersey’s financial sector.
6. The changes aim to strengthen the island’s financial crime framework while minimising operational impacts through industry collaboration.
7. Affected parties should actively engage in the consultation process by providing targeted feedback and preparing for the revised Handbook’s implementation on 1 January 2026.
8. The proposed timeline appears ambitious but feasible, provided JFSC supports industry with mapping documents, webinars, and potentially a transition period.
9. Stakeholders are encouraged to leverage this consultation to shape a proportionate and practical Handbook that aligns with international standards and Jersey’s competitive financial environment.

HERE ARE THE LINKS TO THE PROPOSED CHANGES

1. SUPERVISED PERSONS (LESS NPOs)
   1. Handbook for financial services business and a tracked change version

1. 1. 1.   https://jerseyfsc.org/media/h5ng1g0r/updated-handbook-tracked-changes.pdf https://jerseyfsc.org/media/f2adgchx/updated-handbook-clean-version.pdf

1. 1. Matrix mapping the COP of the existing Handbook to the new version.  

1. 1. 1. https://jerseyfsc.org/media/gidlpc5z/cop-matrix-map.xlsx
2. NPO
1. CFT Handbook for Prescribed Non-Profit Organisations (NPO CFT Handbook).

1. 1. 1. https://jerseyfsc.org/media/ba1gxeik/npo-handbook-clean-version.pdf
   2. Table mapping Section 17 with the new sections of the NPO CFT Handbook

1. 1. 1. https://jerseyfsc.org/media/40rpddzl/npo-handbook-mapping-table.pdf

KEY OBJECTIVES

1. Respond to MONEYVAL Recommended Actions: Clarify obligations and address inconsistencies in applying Handbook requirements, as identified in the JFSC MONEYVAL Action Plan (November 2024).
2. Enhance Usability: Streamline structure, improve readability, and provide more explicit guidance to reduce compliance burdens for industry stakeholders.
3. Introduce Targeted Enhancements: Add new Codes of Practice (COP) for Enhanced Due Diligence (EDD) on complex structures, expand guidance on Politically Exposed Persons (PEPs), beneficial ownership, sanctions, and sector-specific risks for VASPs and DNFBPs.
4. Restructure NPO Guidance: Propose a standalone CFT Handbook for Prescribed NPOs to ensure proportionate supervision.

AFFECTED PARTIES

The proposals impact all supervised persons, including:

• Financial Institutions (FIs)
• Designated Non-Financial Businesses and Professions (DNFBPs), such as real estate agents, lawyers, and accountants
• Virtual Asset Service Providers (VASPs)
• Prescribed Non-Profit Organisations (NPOs)
• Service providers to the above entities

PROPOSED CHANGES

1. Structural Improvements:
• New numbering format for COP to minimise future disruption.
• Enhanced readability with colour, diagrams, and navigation aids (e.g., section footers).
• Glossary relocated to the end of the Handbook.
• Prepaid cards guidance moved to a new section (14) with wire transfers.
2. Clarificatory Amendments:
• Section 4 (Identification Measures): New guidance on control through means other than ownership to clarify beneficial ownership and control.
• Section 6 (Ongoing Monitoring): Expanded to include periodic reviews, trigger events, and enhanced monitoring for high-risk customers, emphasising updating Source of Wealth/Source of Funds and beneficial ownership.
• Section 7 (EDD and Exemptions): Split into separate sections, with a new COP for complex structures and clarified EDD for PEPs, including close associates.
• Sanctions Guidance: Enhanced focus on identifying indirect links and close associates to prevent sanctions evasion.
3. Sector-Specific Guidance:
• VASPs (Section 16): New section addressing VASP-specific risks and typologies.
• DNFBPs (Sections 17–21): Standardised guidance for real estate agents, high-value dealers, lawyers, and accountants, focusing on sector-specific vulnerabilities and red flags.
• NPOs: Proposal to move Prescribed NPO guidance (Section 17) to a standalone CFT Handbook.
4. Supplementary Guidance:
• Updated terminology for Digital ID (formerly EID).
• Clarification that non-executive directors in domestic state-owned entities are not automatically treated as domestic PEPs unless high-risk factors exist.
• New sections on periodic reviews, trigger events, and enhanced monitoring.

GUIDANCE FOR STAKEHOLDERS

1. Review the Draft Documents:
• Access the updated Handbook (tracked and clean versions), NPO CFT Handbook, COP matrix map, and NPO mapping table via the links provided in the consultation.
• Assess how proposed changes impact your organisation’s policies, procedures, and compliance frameworks.
2. Provide Feedback:
• Use the Smart Survey to submit responses directly to JFSC or coordinate through JFL by 4 September 2025.
• Address specific questions (1–9) with practical examples, such as challenging scenarios for identifying PEPs, complex structures, or sanctions indirect links.
• Offer broader feedback (Questions 10–12) on usability, timeline viability, and additional support needs (e.g., transition period, training).
3. Engage with JFSC:
• Participate in the planned webinar or request additional engagement (e.g., townhalls) to clarify proposals.
• Monitor JFSC’s website for updates on engagement opportunities.
4. Prepare for Implementation:
• Anticipate the revised Handbook’s effective date (1 January 2026) and begin aligning internal processes.
• Leverage mapping documents to track changes to existing COP and sections.
• Ensure staff are trained on new requirements, particularly for EDD, ongoing monitoring, and sector-specific guidance.
5. NPO-Specific Considerations:
• Review the proposed standalone NPO CFT Handbook and provide feedback on its proportionality and clarity.
• Assess whether the separation of NPO guidance reduces administrative burdens or requires additional adjustments.

CONSULTATION PROCESS

• Deadline: Comments are due by 11:59 PM on 4 September 2025, via Smart Survey or Jersey Finance Limited (JFL).
• Contact:
• JFSC Policy Team: policy@jerseyfsc.org, +44 (0) 1534822000
• JFL: Tim Hart, timothy.hart@jerseyfinance.com, +44 (0) 1534836010
• Response Handling: Responses are non-confidential unless specified. JFL will anonymise and collate responses for JFSC and archive them for member access.
• Engagement: JFSC plans a webinar and further industry engagement, with details to be published on their website.

QUESTIONS FOR FEEDBACK

The consultation includes 12 questions targeting specific areas (e.g., control through other means, ongoing monitoring, PEPs, complex structures, VASPs, DNFBPs, NPOs) and broader feedback on the Handbook’s enhancements, proposed timeline, and potential support measures (e.g., mapping documents, webinars).

TIMELINE

• Feedback Deadline: 4 September 2025
• Publication of Feedback and Revised Handbook: Early November 2025
• Effective Date: 1 January 2026 (subject to feedback on timeline feasibility)

CONCLUSION

• The JFSC’s proposed enhancements to the AML/CFT/CPF Handbook are a proactive response to MONEYVAL’s Recommended Actions and an opportunity to improve compliance clarity and usability for Jersey’s financial sector.
• The changes aim to strengthen the island’s financial crime framework while minimising operational impacts through industry collaboration.
• Affected parties, including FIs, DNFBPs, VASPs, and NPOs, should actively engage in the consultation process by providing targeted feedback and preparing for the revised Handbook’s implementation on 1 January 2026.
• The proposed timeline appears ambitious but feasible, provided JFSC supports industry with mapping documents, webinars, and potentially a transition period.
• Stakeholders are encouraged to leverage this consultation to shape a proportionate and practical Handbook that aligns with international standards and Jersey’s competitive financial environment.

THE JFSC CONSULTATION ON PROPOSED ENHANCEMENTS TO THE AML/CFT/CPF HANDBOOK HAS BEEN ISSUED: 12 JUNE 2025

The JFSC Consultation on proposed enhancements to the AML/CFT/CPF Handbook is out:-

• READ IT HERE - https://www.jerseyfsc.org/media/rbynfdur/consultation-on-proposed-enhancements-to-the-aml-cft-cpf-handbook.pdf

Overview

1. This consultation paper (CP) seeks feedback on proposals to enhance
1. The JFSC Handbook is for the detection and prevention of money laundering, the countering of terrorist financing, and the countering of proliferation financing (Handbook).
2. There are two key drivers to the proposed enhancements covered within this CP:

1. Clarificatory changes as part of the JFSC, measured and proactive response to MONEYVAL Recommended Actions
2. Enhancements and improvements to the Handbook to improve usability and reduce time/effort in the application

MONEYVAL Recommended Actions (Handbook related only)

1. MONEYVAL Recommended Actions (Recommended Actions) were identified across all agencies, including the JFSC.
1. In November 2024, the JFSC issued the JFSC MONEYVAL Action Plan (Action Plan) detailing the response to the JFSC-related Recommended Actions.

1. 1. 1. https://www.jerseyfsc.org/media/7911/jfsc_moneyval-action-plan_final.pdf
   2. The Action Plan included several actions for which the understanding of and approach to complying with Handbook obligations were inconsistent.
2. This consultation is the JFSC's response to those actions through enhancements to specific, targeted sections of the Handbook.
3. The response outputs noted in 1.1.4 of the consultation are primarily clarificatory amendments to the Handbook.
   • 1.1.4 The Action Plan included several actions where the understanding of and approach to complying with Handbook obligations was inconsistent. This consultation is our response to those actions through enhancements to specific, targeted sections of the Handbook.
4. Having reviewed the relevant sections of the Handbook, the JFSC concluded that the required guidance was essentially already present.
5. However, as noted by the Recommended Actions, the industry could benefit from further refinement and clarification to avoid inconsistency in application.

Enhancements to improve clarity and usability

1. This process has provided an opportunity to streamline and improve the clarity of relevant sections of the Handbook, aiming to make it more accessible and thereby better support industry in complying with its obligations.
2. While the JFSC has drafted comprehensive enhancements to the Handbook, the JFSC is collaborating with industry to align, simplify and clarify expectations.
3. The JFSC also aims to leverage industry experience and working practices by incorporating existing actions and work already undertaken by industry into the guidance to reduce the operational impact of the proposed changes.

Any Additional Feedback

1. While this consultation is focused on specific sections of the Handbook, the JFSC welcome any additional feedback on improvements that could be made to the more exhaustive Handbook, as part of this consultation process.

Read the JFSC full consultation paper.

• https://www.jerseyfsc.org/industry/consultations/consultation-on-proposed-enhancements-to-the-amlcftcpf-handbook/
•  https://www.jerseyfsc.org/news-and-events/consultation-on-enhancements-to-our-amlcftcpf-handbook-published/
• https://www.jerseyfsc.org/media/rbynfdur/consultation-on-proposed-enhancements-to-the-aml-cft-cpf-handbook.pdf