Consultation on facilitating the adoption of Digital ID Systems (No.4 2022)

Summary

This is a joint consultation paper issued by the Government of Jersey and the JFSC seeking industry views on how to increase adoption of Digital ID Systems for meeting customer due diligence (CDD) requirements under Jersey's AML/CFT regime. It sets out three possible policy options and invites written feedback; it does not itself impose new legal requirements.

• Option 1: Provide further clarity within the existing regime by enhancing Section 4 of the AML/CFT Handbook and incorporating Digital ID concepts into law.
• Option 2: Establish an accreditation framework under which Digital ID Systems and their providers would be certified against agreed standards.
• Option 3: Create a new class of regulated business, Digital ID System Service Providers, which would become Supervised Persons subject to JFSC (or another body's) supervision.
• Also raised: Whether a shared 'know your customer' (KYC) utility, previously explored in 2019 to 2020, should be revisited given the growing market of private-sector Digital ID providers.

The consultation is addressed to all Supervised Persons and to Digital ID System providers. Responses were invited by email to the Government or via Jersey Finance Limited's coordinated industry response, with a closing date of 31 August 2022. As a consultation paper in draft status, it creates no binding obligations pending the JFSC's and Government's decisions on which option (if any) to pursue.

Applies to

Supervised Persons, Digital ID System providers, trust company service providers, banks

Deadlines

• 31 August 2022: Closing date for responses to the consultation, including responses submitted via Jersey Finance Limited's coordinated industry response.