Follow-on consultation: AML/CFT/CPF Handbook enhancements complex structures (No. 8 2025)

Summary

This is a follow-on consultation paper from the JFSC seeking industry feedback on revised guidance and codes for complex structures within the AML/CFT/CPF Handbook. It builds on a June 2025 consultation and responds to industry feedback that treating all complex structures as automatically high-risk was disproportionate. The JFSC now proposes splitting the guidance into standard customer due diligence and enhanced due diligence, applying a more risk-based and proportionate approach.

• Section 4 (Standard CDD): Guidance on identifying complex structures and applying mitigating measures where the structure is not assessed as high risk.
• Section 7 (Enhanced CDD): A code and guidance for situations where, after standard measures, the structure remains opaque or lacks legitimate rationale and is assessed as high risk.
• Rationale for revision: Follows feedback from 18 respondents and a funds sector workshop indicating a formulaic approach could unnecessarily capture a large proportion of structures as high risk.
• Who is affected: All supervised persons, including financial institutions, DNFBPs, VASPs, prescribed non-profit organisations, and service providers to those entities.

The JFSC is inviting written comments via Smart Survey (directly or through Jersey Finance Limited) by 12 February 2026. Feedback will inform revised Handbook sections to be published by 26 March 2026, with the updated Handbook proposed to take effect from 31 May 2026, subject to consultation feedback.

Key obligations

• Interested parties wishing to respond must submit comments in writing via Smart Survey (or to Jersey Finance Limited) by 11:59pm on Thursday 12 February 2026.
• Industry bodies or associations submitting comments should also provide a summary of the type of individuals and/or institutions they represent.

Applies to

financial institutions (FIs), designated non-financial businesses and professions (DNFBPs), virtual asset service providers (VASPs), prescribed non-profit organisations (Prescribed NPOs), service providers to those listed, supervised persons

Deadlines

• Thursday 12 February 2026: Deadline for submitting consultation responses (11:59pm), directly or via Jersey Finance Limited
• 26 March 2026: JFSC proposes to publish consultation feedback and revised sections of the Handbook by this date
• 31 May 2026: Proposed effective date for the revised AML/CFT/CPF Handbook, subject to consultation feedback