Consultation on proposed enhancements to the AML/CFT/CPF Handbook (No. 4 2025)

Summary

This is a JFSC consultation paper seeking industry feedback on proposed enhancements to the AML/CFT/CPF Handbook. The changes are driven by JFSC's response to MONEYVAL Recommended Actions and by a broader effort to improve the Handbook's clarity, structure and usability. The document is a draft consultation, not yet in force, and invites written responses by 4 September 2025.

• MONEYVAL-driven clarifications: Additional guidance on beneficial ownership and control through means other than ownership, periodic reviews of high-risk customers (including obtaining Source of Wealth/Source of Funds evidence and updating beneficial ownership data), strengthened sanctions guidance on close associates and indirect links, and clearer PEP and close-associate EDD expectations.
• New EDD provisions: Two new Codes of Practice on EDD for complex structures, and a separate, clarified section on exemptions (making clear exemptions apply only in low-risk scenarios).
• Sector-specific guidance: New standalone sections for Virtual Asset Service Providers (Section 16) and for DNFBPs generally (Section 17), plus separated and standardised sections for real estate agents/high value dealers, lawyers and accountants.
• Structural and usability changes: Restructuring of ongoing monitoring guidance (new sub-sections on periodic reviews, trigger events and enhanced monitoring), a new Codes of Practice numbering format, glossary moved to the end, prepaid card guidance merged with wire transfers, and a proposal to remove the Prescribed NPO section and reissue it as a standalone NPO CFT Handbook.
• Timeframe: JFSC proposes publishing the final revised Handbook by early November 2025, with the amended Handbook coming into effect on 1 January 2026.

The consultation poses twelve specific questions inviting feedback on each proposed area (beneficial ownership/control, periodic reviews and sanctions, PEPs and close associates, complex structures, VASP guidance, DNFBP overview and sector sections, the NPO Handbook split, and the proposed timeframe). No obligations are yet binding; this is a request for comments on proposed Handbook text.

Applies to

Financial Institutions (FIs), Designated Non-Financial Businesses and Professions (DNFBPs), Virtual Asset Service Providers (VASPs), Prescribed Non-Profit Organizations (Prescribed NPOs), service providers to those persons, supervised persons

Deadlines

• 4 September 2025: Deadline to submit written comments/responses to the JFSC consultation (or to Jersey Finance Limited coordinating an industry response).
• early November 2025: Proposed publication date for the final version of the amended Handbook.
• 1 January 2026: Proposed effective date for the amended AML/CFT/CPF Handbook.