Feedback on enhancements to the AML/CFT/CPF Handbook (2025-11-27)

Summary

This is the JFSC's feedback paper summarising responses to Consultation Paper No. 4 2025, which proposed enhancements to the AML/CFT/CPF Handbook addressing seven MONEYVAL recommended actions. It covers 22 responses received across sectors and sets out the JFSC's decisions on which proposed changes will proceed, be revised, or be deferred, along with a timeline for implementation.

• Proceeding as proposed: Most Handbook enhancements will proceed, incorporating industry feedback, covering control through other means, ongoing monitoring, sanctions indirect links, DNFBP and VASP sector guidance, and a new standalone Prescribed NPO CFT Handbook.
• Complex structures: Revised proposals on complex structures are being put out for a further, separate consultation rather than finalised now.
• PEPs: Some proposed changes on PEPs and their social/professional close associates are deferred pending further work with the Jersey Government in 2026.
• Clarifications made: Wording has been refined across several sections (e.g. trigger event definitions, termination expectations, links to suspicious activity reporting) in response to industry comments, without creating new substantive requirements.

The paper sets a firm implementation timetable culminating in an effective date of 31 May 2026 for the enhanced Handbook, including the complex structures provisions (once finalised) and new criminal background check requirements. Firms and other supervised persons should track the follow-on consultation on complex structures and the updated Handbook publications in the interim.

Key obligations

• Supervised persons (reporting entities) must comply with the enhanced AML/CFT/CPF Handbook, including new provisions on complex structures and criminal background checks, from the effective date of 31 May 2026.
• Persons wishing to comment on the revised complex structures proposals must submit feedback before the follow-on consultation period closes on 12 February 2026.

Applies to

Trust company business or trust company service providers, Banks, Fund services businesses, Other regulated financial services businesses (e.g. investment business, insurance, money service business), Designated non-financial businesses and professions (DNFBPs), e.g. lawyers, accountants, estate agents, Virtual asset service providers (VASPs), Prescribed Non-Profit Organisations (NPOs), Family offices, Supervised persons under the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008

Deadlines

• 27 November 2025: Publication of the feedback paper, follow-on consultation paper on complex structures, enhanced AML/CFT/CPF Handbook, Prescribed NPO CFT Handbook, and mapping document.
• 12 February 2026: Feedback period for the complex structures consultation paper closes.
• 26 March 2026: Publication of feedback on the complex structures consultation paper and the updated enhanced AML/CFT/CPF Handbook.
• 31 May 2026: Effective date for the AML/CFT/CPF Handbook, including complex structures provisions and criminal background checks.