The JFSC Q4 2024 Registry Supervision inspection report and feedback

A core focus of the JFSC Registry's “transparency regime” is to ensure that essential beneficial ownership and controller information is adequate, accurate, and up-to-date and can be made available to competent authorities on a timely basis.

To maintain the core focus, the JFSC Registry examination officers meet with relevant individuals and inspect documentation to confirm that the data recorded on the Registry database is correct.

THE JFSC Q4 2024 REGISTRY SUPERVISION INSPECTION REPORT AND FEEDBACK

1. The report provides the Q4 findings [see below] along with examples of good practices [see below] identified during the inspections and face-to-face interviews  

FINDINGS IDENTIFIED

2. Associated parties’ details not kept up to date 
3. Difficulties associated with recording joint ownership in respect of members
4. Lack of understanding of the three-tier test, leading to errors and omissions of beneficial owners and controllers
5. Failure to disclose individuals controlling a CORPORATE TRUSTEE where the JFSC does not regulate them
6. Structure charts that do not clearly outline the ownership structure or provide sufficient details about the individuals or entities with significant ownership interests and control
7. Inadequate identification of executors in the situation where a beneficial owner, controller or significant person is deceased
8. Statutory registers containing inaccurate or outdated information

NO MATERIALITY

9. The JFSC says the findings show that there are no systemic issues of concern, and most discrepancies are minor

GOOD PRACTICE IDENTIFIED

10. Entities who keep up-to-date due diligence documentation with the registers tend to file the correct identification data
11. Entities who are more proactive in updating their registers also maintain accurate data in the JFSC Registry’s records
12. Developing a comprehensive pre-inspection readiness plan to ensure that entities are well-prepared, reducing the risk of oversights and streamlining the inspection process
13. Trust company service providers (TCSPs) that maintain comprehensive documentation of trust structures, ownership, and control information tend to have fewer findings
14. The myParties feature in myRegistry should be used, as this enables users to submit more accurate information

WHAT YOU MUST DO

15. The JFSC encourages boards, senior management, and owner-operators to consider this report's findings and conclusions.

INSPECTION PROGRAMME FOR 2025

16. The JFSC have listened to your feedback and will streamline the inspection process to reduce the burden on resources for Jersey-registered businesses. In 2025:

1. 1. The JFSC will select entities for inspection which are proportionate with the size of the TCSP
   2. REGISTRY SUPERVISION INSPECTIONS and REGULATORY EXAMINATION visits will not be held together
   3. Registry Supervision criteria during 2025 will continue to concentrate on
      1. High-risk indicators and
      2. Politically exposed persons.

SOURCE

https://www.jerseyfsc.org/news-and-events/read-our-q4-2024-registry-supervision-inspection-programme-feedback/