JFSC X8 Sector-based aggregated data revised 31 March 2025

The JFSC has updated and reissued the aggregated data that it has collected on eight industry sectors.

The data in these reports covers the period from 2019 to 2023 and provides a general overview of each sector, along with trends on inherent risk factors such as customers from higher-risk jurisdictions and politically exposed persons (PEPs) connections.

THE EIGHT SECTORS ARE AS FOLLOWS:-

1. FUNDS SECTOR - https://www.jerseyfsc.org/media/8176/20250331-sector-data-funds-1.pdf
2. ACCOUNTANCY SECTOR - https://www.jerseyfsc.org/media/8177/20250326-sector-data-accountancy-1.pdf
3. ESTATE AGENT SECTOR - https://www.jerseyfsc.org/media/8179/20250326-sector-data-estateagent-1.pdf
4. LENDING SECTOR - https://www.jerseyfsc.org/media/8178/20250326-sector-data-lenders-1.pdf
5. BANKING SECTOR - https://www.jerseyfsc.org/media/7988/sector-data-banking-5.pdf
6. TRUST COMPANY BUSINESS SECTOR -   https://www.jerseyfsc.org/media/7985/sector-data-tcb-6.pdf
7. LEGAL SECTOR - https://www.jerseyfsc.org/media/7986/sector-data-legal-sector-5.pdf
8. INVESTMENT BUSINESS SECTOR - https://www.jerseyfsc.org/media/7987/sector-data-ib-6.pdf

THE JFSC SAYS

1. The aim of publishing these reports is to enhance the understanding of money laundering and terrorist financing risks within each sector and facilitate comparison across different industries and activities.
2. Key risk indicators are included for each sector to provide valuable benchmarks for supervised persons assessing their own money laundering and terrorist financing risks.
3. The reports are not risk assessments.
4. An explanation has been provided to support the aggregated data presented through a combination of graphs and tables.
5. While some data quality and integrity checks are performed upon receipt of the data, the JFSC relies on the accuracy and completeness of the data provided by the industry.
6. The JFSC will engage with the industry through trade bodies and associations during Q1 2025 to gather feedback and inform future publications.

A SUMMARY OF EACH SECTOR REPORT IS SHOWN BELOW:-

FUNDS SECTOR

Read the JFSC data report for the funds sector. https://www.jerseyfsc.org/media/8176/20250331-sector-data-funds-1.pdf

1. COUNTRY EXPOSURE,
   1. Jersey has a significant funds sector with a similar geographical reach, encompassing 168 jurisdictions,
   2. Compared to the 171 reported by the TCB sector.
2. Jersey offers collective investment funds (CIFs) and private fund products, with the current primary target market being professional investors.
3. The principal activity undertaken by Fund Services Businesses (FSB) is the provision of fund administration and management services.
4. The JPF remains the growth product in terms of the number of funds; however, CIFs continue to dominate in terms of the number of investors and assets under management.
5. In 2023, 13.6% of CIF investors/beneficial owners are reported as residents in higher-risk jurisdictions,
   1. With the vast majority, 12.9%, from South Africa, which was added to the FATF Grey List in February 2023.
6. Except for South Africa, only a small percentage of both CIF and JPF total investors/beneficial owners are from higher-risk jurisdictions.
   1. The number of fund investors/beneficial owners reported as residents in one of the jurisdictions of interest for terrorist financing is very low for both CIFs and JPFs, with both trends declining over the reporting period from 2019 to 2023.
7. The number of reported connections to politically exposed persons (PEPs) has increased in both CIFs and JPFs.
   1. However, when considered as a percentage of total reported investors/beneficial owners, the CIFs' trend is rising, while the JPFs' trend is decreasing.
8. PEPs are not evenly distributed through the CIFs and JPFs in 2023:
   1. JPFs
      1. i.38% of JPFs reported one or more PEP connections
      2. 70% of the PEP connections by number reported by 10% of the JPFs

2. CIFs

1. 1. 1. 48% of CIFs reported one or more PEP connections
      2. 76% of the PEP connections by number reported by 10% of the CIFs

9. CIFs:
1. Certified/Recognized Funds: A CIF granted a certificate or permit by the JFSC with a collective investment of capital by way of the public offer. Provided services by an FSB.
2. Unregulated Funds: A CIF that meets, and continues to meet, the eligibility criteria of the Collective Investment Funds Unregulated Funds (Jersey) Order 2008. Provided services by an FSB.
10. Private funds:
1. Jersey Private Funds (JPFs): A private fund vehicle launched in April 2017. Must be offered to a restricted circle of persons, which must not include retail investors, and must always have 50 or fewer offers/investors. Provided services by a Designated Service Provider (DSP).
2. Legacy Private Funds: Prior to April 2017, there were various types of private funds collectively referred to as the Legacy Private Funds. This comprises a COBO-only Fund, a Private Placement Fund, and a Very Private Fund. These could not be established after April 2017.

ACCOUNTANCY SECTOR

Read the JFSC data report for the accountancy sector. https://www.jerseyfsc.org/media/8177/20250326-sector-data-accountancy-1.pdf

1. The supervised persons that comprise the sector vary significantly in terms of size, geographic reach, client profiles and the services provided.
2. The sector includes the Big Four accountancy firms, which have an international reach, as well as sole traders, which have a predominantly domestic focus and account for nearly 40% of the sector.
3. Overall, the sector is relatively small, accounting for less than 4.5% of the total revenue in the financial services sector.
4. The Big 4 accountancy firms dominate, generating approximately 66% of the reported income and employing nearly 60% of the reported staff. According to the data collected, tax advice is the most common service provided, followed by accountancy services, audit and insolvency.
5. Data collected regarding the residency of the sector’s customers demonstrates that, in 2023, over 77% of all customers are Jersey residents, with a further 10% residing in the United Kingdom.
6. Exposure to higher-risk jurisdictions is relatively low, and, as with other sectors, the higher-risk jurisdictions with the most significant number of reported customer relationships are
1. South Africa,
2. Followed by Monaco.  
7. Connections to terrorist financing jurisdictions of interest are very low.
8. The level of PEP connections is similar to that in the legal sector, with 4.4% of reported customer relationships involving a PEP connection, compared to 4.1%.
9. Overall, PEP connections are most significant where the customer is a company.
10. The key risk indicators have been split between larger firms with 50 or more employees, smaller firms with fewer than 50 employees and sole traders.
11. This split acknowledges that these may have different risk profiles due to their customer focus.
12. The data demonstrate that larger firms are more likely to have higher-risk customers and politically exposed persons (PEPs) but, conversely, are also more likely to have applied enhanced customer due diligence. 

ESTATE AGENT SECTOR

Read the JFSC data report for the estate agent sector. https://www.jerseyfsc.org/media/8179/20250326-sector-data-estateagent-1.pdf

1. The estate agency sector in Jersey comprises those involved in the buying or selling of property.
2. The property may be either residential or commercial and can be held as either freehold (including flying freehold) or leasehold.
3. It may also involve share transfer and can be based in Jersey or outside of Jersey. The sector does not include those selling new-build properties' off-plan” nor the activity of managing properties, including lettings.
4. In 2023, Jersey resident individuals accounted for just over 89% of the reported customers, with Jersey companies representing nearly another 8%.
5. The small number of non-Jersey resident customers (approximately 3%) is almost entirely comprised of customers from the UK and Guernsey.
6. Overall, the data indicate that the majority of transactions involve residential Jersey property, which is freehold, leasehold, or leasehold with a right to buy rather than share transfers.
7. Given the profile of the transactions, combined with customers completing one-off transactions rather than entering into business relationships, the year-on-year trend reflects the buoyancy, or otherwise, of the Jersey housing market.
8. In 2023, the data indicate a substantial decline in sales, which is consistent with reports from the legal sector and housing market statistics published by the Government of Jersey.

LENDING SECTOR

Read the JFSC data report for the lender sector. https://www.jerseyfsc.org/media/8178/20250326-sector-data-lenders-1.pdf

1. In addition to banks, Jersey supports other financial institutions that grant loans, primarily to the local population. The lenders' (non-bank) report includes data from these lenders; it excludes lending by any person also registered with the JFSC under another regulatory law, such as deposit takers (banks).
2. This population of lenders is varied, including both large and small businesses, with some actively lending and others having a loan book in runoff. The nature of the lending activities includes personal and consumer loans (including vehicle finance), asset-backed finance, as well as business loans and property lending, encompassing mortgages and bridging finance. Consumer lending is primarily short-term (1-5 years) and unsecured, except for vehicle loans and mortgages.
3. The total amounts lent by this sector are significantly lower than the value of loans made by banks (see the data report for banks published in December 2024).
4. In 2023, approximately 93% of the customers were reported by just over 21% of the reporting entities; just over 92% of the customers were reported as individuals; and nearly 73% of the customers/beneficial owners were reported as being Jersey resident (in total 99.7% of the customers/beneficial owners are reported as resident in the UK or a Crown Dependencies).

BANKING SECTOR

Read the JFSC data report for the banking sector. https://www.jerseyfsc.org/media/7988/sector-data-banking-5.pdf

1. The banking sector in Jersey is relatively stable in terms of the number of licenced entities, employees, and the total number of customer relationships. Total deposits have steadily increased from £113 billion in 2016 to £156 billion as of the end of 2023.  
2. The data collected relates to both deposit-taking and bank lending. It highlights the global reach of the sector, with customers or beneficial owners of customers reported in 206 jurisdictions, and 62% of deposit customers being residents outside of Jersey.
3. Over the period analysed, exposure to higher-risk jurisdictions has been impacted by changes to the FATF list of jurisdictions identified as having strategic deficiencies. In particular, South Africa was added to the FATF “grey list” in February 2023—a jurisdiction that ranks 6th in terms of the residency of deposit customers.  
4. The number of banking customers who are, or are connected to, a politically exposed person (PEP) has steadily grown since 2019.
5. In September 2023, the Money Laundering (Jersey) Order 2008 was amended to permit the declassification of Politically Exposed Persons (PEPs).
6. In 2023, 5 of the 19 banks that provided data had declassified one or more politically exposed persons (PEPs). 
7. The key risk indicators have been split between banks with a high street presence in Jersey (retail banks) and banks which primarily provide corporate banking solutions (corporate banks).
8. This split acknowledges that these banks may have different risk profiles due to their customer focus.
9. The data demonstrate that customers of corporate banks are more concentrated in higher-risk jurisdictions, are more likely to be connected to a politically exposed person (PEP), and are rated as higher risk by the banks compared to retail bank customers. 

TRUST COMPANY BUSINESS SECTOR

Read the JFSC data report for the trust company business sector. https://www.jerseyfsc.org/media/7985/sector-data-tcb-6.pdf

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 demonstrate the international nature of Jersey’s TCB sector, with customers reported from 171 different jurisdictions, and the vast majority of customers are reported as being residents outside of Jersey.
4. In 2023, 7.8% of TCB reported non-Jersey customer relationships came from higher-risk jurisdictions,
1. With just under half of these, or 3.4%, originating from South Africa.
5. Other prominent higher-risk jurisdictions include
1. Kenya (1.0%),
2. Monaco (0.9%),
3. Lebanon (0.9%), and
4. Russia (0.3%).  
6. The proportion of customers from higher-risk jurisdictions associated with terrorist financing
1. Decreased from 2.4% in 2021 to
2. 1.6% in 2023, primarily due to a decline in Russian customers. 
7. Based on 2023 data, the TCB sector has the highest level of PEP connections,
1. Accounting for 14.7% of the total number of reported customer relationships, with the total number of PEP connections steadily increasing throughout the reporting period.  
8. The data demonstrate that enhanced customer due diligence (CDD) has been applied to 60% of customer relationships, reflecting the sector’s conservative approach to onboarding new customers. 
9. The sector offers a full range of trust and company activities, with management services being the activity most often provided to customers.
10. Whilst management services activity represents 67.5% of the reported activity in 2023, this is a decrease from the high of 75% in 2020.
11. Over the same period, there has been an increase in the provision of trustee-only services.  

LEGAL SECTOR

Read the JFSC data report for the legal sector. https://www.jerseyfsc.org/media/7986/sector-data-legal-sector-5.pdf

1. The legal sector data covers law firms registered with us, which vary significantly in terms of size, geographic reach, client profiles and the services provided.
2. Some law firms are involved in large, multi-national transactions, where they often play a discrete role, and others have a customer base that is predominantly domestic.  
3. Given the one-off, transactional nature of some legal services, year-on-year trends can be less stable than in other sectors; however, they provide valuable insights into the risks within the industry.  
4. Data collected regarding the residency of the law firm’s customers demonstrates that, in 2023,
1. Half of all customers are Jersey residents,
2. With a further 22% residing in the United Kingdom.
5. Exposure to higher-risk jurisdictions is stable and relatively low compared to other financial services sectors in Jersey.
6. As with other sectors analysed, the higher-risk jurisdiction with the most significant number of customer relationships is
1. South Africa,
2. followed by Monaco and
3. Lebanon.  
7. 4.1% of the law firm’s customer relationships include a PEP connection. This is the highest for Jersey vehicles, such as
1. Limited partnerships (16.6%),
2. Followed by Trusts with a non-Jersey trustee (10.7%) and
3. Trusts with a Jersey trustee (9.2%).
8. PEP exposure is highest among more prominent law firms where the provision of services to trusts, companies and other legal arrangements is more common. 
9. The data shows a reduction in 2023 in the number of matters relating to the buying and selling of immovable property and business entities, which is consistent with data published by Statistics Jersey, indicating a decline in property sales in Jersey in 2023. 

INVESTMENT BUSINESS SECTOR

Read the JFSC data report for the investment business sector. https://www.jerseyfsc.org/media/7987/sector-data-ib-6.pdf

1. The activity of investment businesses (IBs) is undertaken by a diverse range of businesses, including local independent financial advisers (IFAs), niche wealth managers, and banks with a global presence.  
2. IB is divided into 5 “classes” (A, B, C, D, and E), with this reporting focusing on classes A–D, as class E is rarely used. These include dealing in investments (Class A), managing investments (Class B), giving investment advice when not prevented from holding client (Class C) and giving investment advice when prevented from holding client assets (Class D).  
3. Over the period from 2019 to 2023, the value of total assets under administration (or an equivalent measure) peaked in 2021 but has generally grown in line with the total assets under administration, in custody, managed, or advised, increasing from £121 billion in 2019 to £137 billion in 2023.
4. This includes significant growth in the value of assets advised by Class D entities, which has increased from £3.9 billion in 2019 to £11.3 billion in 2023.
5. Over the same period, the number of firms has declined due to a combination of banks ceasing to operate in Jersey, as well as the consolidation of non-bank investment banks within the sector.  
6. Much of the data analysed has been split between banks which provide IB services and non-bank IBs.
7. This demonstrates that, in general, banks have a higher proportion of customers from higher-risk jurisdictions, more connections to politically exposed persons, and consider their customers to be at a higher risk of money laundering and terrorist financing (ML/TF). This increased inherent risk may be partially mitigated by the heightened levels of enhanced CDD applied to banks’ IB customers in comparison to non-bank IBs.   

SOURCE

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