Updates to our 2024 supervisory risk data collection (2024-09-27)

Summary

This JFSC guidance note explains changes to the 2024 supervisory risk data collection (SRDC) exercise, which will run in January 2025, and previews changes planned for future years. It covers new and revised data points, a new late filing fee mechanism for non-submission, and adjustments to which entities must complete certain workbooks.

• New data points in 2024 SRDC: Sector workbooks will add a question on customers conducting Sound Business Practice Policy activities and a question breaking down complaints into categories (poor administration, CDD process, fees/charges, mis-selling, withdrawal/refusal of services, fraud, non-payment of claim, transaction error).
• AMLSP-serviced Schedule 2 businesses: For the first time, AMLSPs will be issued a workbook to provide five footprint data points (risk rating, customer numbers, PEP counts, total income, SAR numbers) on the Schedule 2 businesses they service; liability for the data and any late filing fee rests with the supervised person, not the AMLSP.
• DNFBP group structure data: A new two phase collection on DNFBP group structures begins: phase one is an ad hoc myJFSC exercise for certain DNFBPs issued in early October 2024 with a 4 week submission window; phase two covers TCSPs (including AMLSP-serviced ones) via a new workbook/tab issued alongside the 2024 SRDC.
• NPO data collection: TCB administered NPOs continue reporting via myJFSC as before; independent Prescribed NPOs will move to ongoing annual SRDC reporting (initially by online survey, later via myJFSC); independent registered NPOs (non Prescribed) are excluded from the 2024 SRDC.
• Data validation: Eight mandatory Section I Global Footprint questions (A1, A2/A3, A17-A19, A21) will be system validated; incomplete submissions will fail validation and must be resubmitted.
• Late filing fees: Failure to complete and return SRDC requests by the JFSC's deadline is a Code of Practice breach and may result in a late filing fee under the fees notices.
• Workbook changes: The TCB private trust company (PTC) workbook is withdrawn because PTCs now register directly with the JFSC; Category A insurance permit holders that do not meet the 'in or from within' test are excused from the insurance business workbook but must still complete the Section I footprint workbook.
• Deferred/future changes: Prudential questions proposed in 2023 will not be included in future SRDCs; conflict of interest categories, wire transfer purpose of payment categories, and Jersey Resolution Authority questions are deferred beyond the 2024 SRDC; additional product/service questions arising from the 2024 MONEYVAL report may be added for the 2025 SRDC (collected in 2026).

Overall, reporting entities should prepare systems and records now to capture the new data fields ahead of the January 2025 collection and the October 2024 DNFBP ad hoc exercise, and should ensure timely submission to avoid late filing fees.

Key obligations

• Reporting entities must complete and submit the relevant 2024 SRDC sector workbook, including new questions on Sound Business Practice Policy customers and categorised complaint numbers.
• AMLSPs must provide the requested footprint data (risk rating, customer numbers, PEP counts, income, SAR figures) for each Schedule 2 business customer entity they service; the underlying supervised person (not the AMLSP) remains liable for timely and accurate submission and any resulting late filing fee.
• DNFBPs supervised by the DNFBP/NPO/VASP team must complete the phase one ad hoc DNFBP group structure workbook via myJFSC within a 4 week submission timeframe from issuance in early October 2024.
• TCB registered persons must complete a new ad hoc DNFBP groups workbook issued alongside the 2024 SRDC, within the same timeframe as the SRDC.
• TCSPs serviced via an AMLSP must provide DNFBP group data under a separate tab of the AMLSP 2024 SRDC workbook.
• TCB administered NPOs and independent Prescribed NPOs must provide supervisory risk data annually (via myJFSC or online survey as applicable); independent registered (non-Prescribed) NPOs are not required to report for 2024.
• All insurance business permit holders, including those exempted from the insurance sector workbook, must still complete the Section I footprint workbook.
• Reporting entities must ensure the eight mandatory Section I Global Footprint questions are fully answered; if validation fails, the workbook must be resubmitted with the missing fields completed.
• Reporting entities must complete and return any JFSC risk questionnaire/SRDC request by the deadline provided, and provide information via the JFSC's online portal where specified; failure to do so is a Code of Practice breach that may trigger a late filing fee.

Applies to

deposit-taking businesses (banks), trust company businesses (TCB registered persons), investment business, fund services business, AIF services business, money service businesses, general insurance mediation business (class P or Q), insurance business permit holders (including Category A and long-term business), designated non-financial businesses and professions (DNFBPs), anti-money laundering service providers (AMLSPs), Schedule 2 businesses serviced via AMLSPs, TCB administered non-profit organisations, independent Prescribed non-profit organisations, registered persons, supervised persons

Deadlines

• January 2025: The 2024 supervisory risk data collection (SRDC) exercise will be conducted.
• early October 2024: JFSC intends to issue the phase one ad hoc DNFBP groups data collection via myJFSC.
• 4 week submission timeframe: Submission window for the phase one ad hoc DNFBP groups data collection issued via myJFSC (and for the TCB ad hoc DNFBP groups workbook issued with the 2024 SRDC).
• 2026: Anticipated year in which the 2025 SRDC for independent Prescribed NPOs will be collected via myJFSC, and in which the 2025 SRDC incorporating MONEYVAL-related product/service data is due to be collected.