THE JFSC meets with select regulatory CONSULTANTS

On 18 September 2025, the JFSC welcomed a focus group of representative regulatory CONSULTANTS to a seminar, hosted by:

• Jenna Caunce, Senior Manager, Heightened Risk Response
• Danielle Sheldon, Director of Enforcement

The event provided

• A valuable forum for open dialogue, reflection on recent enhancements, and a collaborative exploration of the challenges and opportunities facing Jersey’s regulatory landscape.

Building on last year’s 2024 engagement

• The JFSC have continued to listen to the feedback and experiences shared by regulatory CONSULTANTS.
• Over the past year, the JFSC engaged directly with many to understand better the evolving landscape and the practical realities of your work within Jersey’s finance industry.

Several common themes emerged from these conversations:

• Regulatory benchmarking:
• Following Jersey’s positive MONEYVAL assessment, CONSULTANTS have observed a reduction in the use of proactive compliance health checks
• Technology adoption:

• Firms are not consistently leveraging technology to enhance compliance, with investments often focused on cost savings rather than effectiveness

• Board autonomy:

• Local boards, particularly those within larger groups based outside of Jersey, sometimes lack autonomy or access to resources for compliance matters

In response to feedback from last year’s event, the JFSC have implemented several key enhancements to processes:

• Clarity and consistency in appointments:

• Moved to primarily requiring remediation effectiveness testing (RET) under formal notice, providing greater structure and clarity for all parties

• Comprehensive reporting:

• Regulatory CONSULTANTS are required to comment on root causes and any other non-compliance identified during engagements, ensuring critical insights are not lost due to scope constraints

• Timely information sharing:

• Notices now require regulatory CONSULTANTS to comment on the timeliness of information and documentation received, encouraging earlier and more proactive engagement from firms

• Tripartite meetings:

• Introduced tripartite meetings at the outset of engagements to ensure all parties have a clear understanding of the issues and scope, supporting the delivery of high-quality, fit-for-purpose reports

• Feedback and continuous improvement:

• A new feedback process for RET reports has been implemented, designed to drive greater consistency and quality in reporting by highlighting strengths and areas for enhancement

IMPORTANT UPDATE

• Greater flexibility in consultant nominations:

• While the JFSC continue to name three CONSULTANTS in notices, firms now have the option to propose their own appointee, provided they can demonstrate the necessary expertise and address any conflicts of interest

Root causes and common issues

The seminar also explored the root causes of non-compliance identified by the JFSC’s Heightened Risk Response team, including:

• Corporate governance:

• Effective risk management and board oversight are critical; weaknesses stemming from a lack of board engagement with compliance functions and inadequate ownership of remediation actions can lead to broader issues within a firm

• Compliance culture:

• A strong compliance culture is essential to operating a compliant firm; where a firm views compliance as a cost, it is at risk of high compliance staff turnover and ineffective remediation

• Remediation failures:

• Repeat findings and unsustained remediation efforts can lead to regulatory action

From an enforcement perspective,

• Recurring issues identified include inadequate board oversight (particularly when group influence is strong), ineffective customer risk assessments, and inadequate ongoing monitoring.

Looking ahead

• The seminar concluded with a roundtable discussion on enhancing RET guidance and a panel Q&A session with members of the JFSC’s senior leadership team.

 Source

https://www.jerseyfsc.org/news-and-events/strengthening-collaboration-insights-from-the-regulatory-CONSULTANTS-seminar/