Ms Julie Ann Harrigan (R) (2023-05-12)

Summary

This is a public statement issued by the Jersey Financial Services Commission (JFSC) naming Ms Julie Ann Harrigan and disclosing directions issued against her under the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008 and equivalent Regulatory Laws. It follows her 2021 conviction for fraudulent conversion while working as a Jersey solicitor, after which the JFSC determined she is not a fit and proper person under the Supervisory Bodies Law.

• Restriction imposed: Ms Harrigan is prohibited from performing any function for, being employed by, or holding any position in a Schedule 2 business, without prior written approval of the JFSC.
• Wider restriction: Equivalent directions under the Regulatory Laws prevent her from performing any function, employment or position at all in any business regulated by the JFSC, without prior written JFSC approval.
• Offence for non-compliance: Ms Harrigan commits an offence under Article 23(15) of the Supervisory Bodies Law if she fails to comply with the directions.
• Offence for third parties: Any person who knowingly allows her to perform a function, take employment, or hold a position in contravention of the directions is also guilty of an offence.

The statement is primarily informational for the industry and does not create ongoing compliance obligations for regulated firms generally, other than the duty not to knowingly engage or employ Ms Harrigan in contravention of the directions.

Key obligations

• Ms Harrigan must not perform any function for, engage in employment by, or hold any position in a Schedule 2 business without prior written JFSC approval
• Ms Harrigan must not perform any function, engage in employment, or hold any position in any JFSC-regulated business without prior written JFSC approval
• Any person or business must not knowingly allow Ms Harrigan to perform a function, take employment, or hold a position in contravention of the directions

Applies to

Schedule 2 businesses, businesses regulated under the Financial Services (Jersey) Law 1998, Banking Business (Jersey) Law 1991, Collective Investment Funds (Jersey) Law 1998 and Insurance Business (Jersey) Law 1996