Consultation No. 7 of 2026: Changes to the reliance and money laundering compliance officer regimes

Summary

This is a JFSC consultation paper (No. 7 of 2026) proposing changes to the AML/CFT/CPF Handbook to align with amendments made to the Jersey Money Laundering Order (MLO) in April 2026. It covers two areas: the Money Laundering Compliance Officer (MLCO) regime and the reliance regime (reliance on identification measures carried out by another obliged person). The proposals aim to reduce compliance costs and introduce a more risk based, proportionate approach, and the JFSC is seeking industry feedback before finalising Handbook changes.

• MLCO framework changes: Proposes a new Code of Practice (COP18A) letting supervised persons decide, based on size and risk, not to appoint an MLCO; clarifies that MLCO responsibility can be decoupled from day to day compliance monitoring functions, which may be supported by another suitably skilled person; and proposes that firms without an MLCO be exempt from compliance monitoring arrangements while the board retains responsibility for AML/CFT/CPF obligations.
• Reliance framework changes: Removes the mandatory testing requirement (effective 31 October 2026) and replaces it with a risk based 'adequate steps' standard (proposed COP53); allows reliance on an obliged person for information on the purpose and nature of a business relationship; clarifies rules on eKYC/Digital ID providers (reliance can be placed on an obliged person using an eKYC provider, but not directly on the eKYC provider itself); introduces a requirement to periodically obtain updated written assurances; revises the 'without delay' standard for providing evidence of identity; sets out new statutory circumstances (Articles 16(9A) and 16(9B) of the MLO) triggering cessation of reliance; updates the Appendix C written assurance template; and proposes removing the two Group reliance Codes of Practice as duplicative of statute.
• Consultation process: The JFSC invites written responses via a published response form, indicating support, support with concerns, or no support for each question, with industry body respondents asked to describe who they represent.

No changes take legal effect through this document itself; it is a draft consultation and the proposals will only become binding once the Handbook is formally updated following review of responses. Underlying MLO amendments are already partly in force (30 June 2026) or take effect from 31 October 2026, and the Handbook proposals are intended to track those statutory changes.

Key obligations

• Stakeholders wishing to comment must submit responses using the published consultation response form by 5:00pm on 18 August 2026
• Industry body or trade association respondents must include a brief description of the individuals or institutions they represent when submitting a response

Applies to

supervised persons, obliged persons, Money Laundering Compliance Officers, industry bodies and trade associations

Deadlines

• 5:00pm on 18 August 2026: Deadline for submitting feedback on the consultation paper
• 30 June 2026: Some MLO derived amendments to the MLCO framework (e.g. COP18 update on decoupling MLCO monitoring support) already came into force
• 31 October 2026: Removal of mandatory testing requirement and remaining MLO amendments to the reliance and MLCO frameworks take effect