AML/CFT

Who is caught

Jersey's AML/CFT perimeter is built on two overlapping registration regimes, supplemented by beneficial ownership rules and virtual asset requirements. The instruments indexed here catch both persons registered to carry on regulated financial service business and the wider category of Schedule 2 financial services businesses supervised for financial crime purposes.

Regulated financial service business

• Financial service business: Under the Financial Services (Jersey) Law 1998, investment business, fund services business, AIF services business, trust company business, money service business and general insurance mediation business carried on in or from Jersey require registration with the JFSC.
• Insurance permit holders: Permit holders licensed under the Insurance Business (Jersey) Law 1996 are within scope of the Insurance Business Code of Practice, which carries AML/CFT/CPF expectations.
• Sole traders: Natural persons registered to carry on a single class of trust company business (for example Class G director or Class L trustee) are caught, with corporate-oriented requirements applied in modified form.

Schedule 2 businesses

Under the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008 and Schedule 2 to the Proceeds of Crime (Jersey) Law 1999, financial institutions, designated non-financial businesses and professions (DNFBPs), virtual asset service providers (VASPs) and trustees of express trusts must register with the JFSC where they conduct in-scope activity as a business.

• Conducted as a business: JFSC guidance on Article 36 of the Proceeds of Crime Law uses non-exhaustive indicators (holding out to the public, profit motive, level of compensation, multiple activities or customers) to decide whether an activity is carried on as a business and so triggers registration.
• In or from within Jersey: A non-Jersey entity is in scope if managed and controlled from Jersey, physically present in Jersey, or operating through employees or agents with a degree of permanence in Jersey.
• VASPs: Providing a platform for virtual asset dealing, or services over instruments enabling control of virtual assets (such as custody of cryptographic keys), brings a person within the VASP definition even without dealing on its own account.

Beneficial ownership

The Financial Services (Disclosure and Provision of Information) (Jersey) Law 2020 applies to Jersey companies, foundations, incorporated limited partnerships, limited liability companies, limited liability partnerships and separate limited partnerships, which must disclose beneficial ownership and significant person information to the JFSC for AML/CFT purposes.

Sources: Financial Services (Disclosure and Provision of Information) (Jersey) Law 2020 · Financial Services (Jersey) Law 1998 · Insurance Business Code of Practice · Registry guidance on beneficial ownership and control (Last revised 2026-03-31) · Guidance on interpretation of 'in or from within Jersey' for the purposes of Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008 · Guidelines on interpretation of Article 36 of the Proceeds of Crime (Jersey) Law 1999 · Guidance Note: Natural Persons carrying on a single class of Trust Company Business · Travel Rule guidance note

Key duties

Continuing obligations centre on registration, ongoing notification, periodic filings, governance appointments and record-keeping. Several duties carry fixed deadlines.

Registration and licensing

• Financial service business: A person must not carry on financial service business in or from Jersey unless registered under the Financial Services (Jersey) Law 1998, and must comply with applicable Codes of Practice.
• Schedule 2 registration: Persons conducting Schedule 2 activities as a business must register with the JFSC under the Supervisory Bodies Law, specifying all activities conducted, at registration and on an ongoing basis.
• AMLSP regime: An eligible fund services business or trust company business may act as an Anti-Money Laundering Services Provider only after obtaining the JFSC's no objection to its proposed AMLSP MLCO and MLRO; a customer may outsource AML/CFT/CPF activities to an AMLSP but cannot delegate its underlying responsibility as a Schedule 2 business.

Notification duties

• Beneficial ownership changes: Under the Disclosure Law and Registry guidance, an entity must notify the Commission of any change, error or inaccuracy in significant person or beneficial owner information within 21 days of becoming aware.
• Nominated person: Each entity must appoint at least one eligible nominated person; if one resigns or is removed leaving none, a replacement must be appointed and notified within 21 days.
• Material matters: Registered persons must notify the JFSC of changes in principal persons, key persons, shareholdings or LLC interests, and of any matter material to JFSC supervision or the fitness of principal or key persons.
• JPF material issues: Designated Service Providers of Jersey Private Funds must notify material issues via the prescribed online form within 28 calendar days of becoming aware, rather than waiting for the annual return.

Periodic filings

• Annual confirmation statement: Each entity under the Disclosure Law must confirm to the Commission that its held information remains accurate within the relevant period (1 January to end of February each year following establishment, or as otherwise prescribed).
• Sole trader annual form: A natural person carrying on trust company business must submit the Annual Registration Fee and Update Form for Sole Traders by 31 January each year, with a signed compliance declaration.
• Insurance Annual Declaration: Insurance permit holders must submit an Annual Declaration confirming compliance with the Code and AML/CFT/CPF requirements, noting any material exceptions.
• Supervisory risk data collection: Registered and supervised persons must complete the JFSC's annual SRDC; the 2025 SRDC is issued on 2 February 2026 with submission due by 30 April 2026.
• JPF Annual Return: DSPs must complete the JPF Annual Return accurately and in full and positively confirm compliance with the Money Laundering (Jersey) Order 2008.

Governance, monitoring and records

• Compliance function: Codes of Practice require a compliance function including a Compliance Officer, Money Laundering Reporting Officer and Money Laundering Compliance Officer; sole traders are deemed their own compliance officer under the Money Laundering (Jersey) Order 2008.
• Compliance monitoring plan: Registered and supervised persons must maintain a documented, risk-based compliance monitoring plan covering regulatory, financial crime and AML/CFT/CPF obligations, reported to the board and, for group firms, adapted to Jersey-specific risks.
• Risk assessments and CDD: Firms must carry out customer due diligence, transaction monitoring, screening, suspicious activity reporting and record-keeping under the Money Laundering (Jersey) Order 2008 and the AML/CFT/CPF Handbook, and prepare business and customer risk assessments.
• Travel Rule: VASPs must maintain a functioning Travel Rule solution ensuring required originator and beneficiary information accompanies virtual asset transfers, with a risk-based approach to non-Travel Rule jurisdictions and unhosted wallets.
• Remediation: Where an Examination or other finding identifies deficiencies, registered persons are expected to prepare and submit a remediation action plan, with the JFSC having low tolerance for plans running beyond 12 months.

Sources: Financial Services (Disclosure and Provision of Information) (Jersey) Law 2020 · Financial Services (Jersey) Law 1998 · Insurance Business Code of Practice · Investment Business Code of Practice · Money Service Business Code of Practice · Registry guidance on beneficial ownership and control (Last revised 2026-03-31) · Guidance Note: Compliance Monitoring · Jersey Private Funds Annual Compliance Returns · Guidance Note: Natural Persons carrying on a single class of Trust Company Business · Travel Rule guidance note · Updates to our 2024 supervisory risk data collection (2024-09-27) · Updates to our 2025 supervisory risk data collection · Guide to Anti-Money Laundering Services Provider Application Process

Exemptions and carve-outs

The instruments provide a number of carve-outs, both from registration and from specific AML/CFT obligations.

Out of scope of registration

• Non-professional trustees: Non-Professional Trustees of express trusts are deemed financial services business but are not required to register with the JFSC, though they remain subject to AML/CFT/CPF obligations as modified by the Non-Professional Trustees Order 2016.
• Financial institution exclusions: FI activities must be conducted for or on behalf of a customer to be in scope; intra-group, employee and sole-owner arrangements are generally excluded unless third parties or other activities bring them into scope.
• Activity from outside Jersey: Schedule 2 activity provided solely from outside Jersey through marketing or targeting Jersey clients is not treated as carried on in or from within Jersey; nor is advice merely because it is received in Jersey, or a service merely because a customer gives effect to a contract from Jersey.
• Overseas persons: An overseas person dealing with, acting as agent for, or carrying out discretionary management for a person in Jersey is not treated as carrying on business in or from within Jersey solely because that person is in Jersey.

Relief from specific obligations

• Low risk businesses: Financial services businesses may be exempted from considering the Sound Business Policy in their risk assessments where exempted under the Proceeds of Crime (Low Risk Financial Services Business) (Jersey) Order 2024.
• Sole trader Schedule 2 directors: Until 30 September 2024, certain AML/CFT/CPF governance requirements (risk assessment, written policies, MLRO appointment) were temporarily disapplied to individual sole trader Schedule 2 directors, though CDD, monitoring, SAR filing, sanctions reporting and record-keeping continued to apply.
• Travel Rule thresholds: For virtual asset transfers below EUR 1,000, verification of payer information is not required absent suspicion of money laundering or terrorist financing; transfers within the same VASP or between VASPs acting on their own behalf are out of scope.
• Insurance workbook: Category A insurance permit holders that do not meet the 'in or from within' test are excused from the insurance business SRDC workbook but must still complete the Section I footprint workbook.
• General registration exemptions: The Financial Services (Jersey) Law 1998 contains schedules exempting specified categories of activity or person from registration; the summaries do not enumerate these.

Sources: Financial Services (Jersey) Law 1998 · Guidance on interpretation of 'in or from within Jersey' for the purposes of Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008 · Guidelines on interpretation of Article 36 of the Proceeds of Crime (Jersey) Law 1999 · Sound Business Policy · Travel Rule guidance note · Updates to our 2024 supervisory risk data collection (2024-09-27) · Schedule 2 Supervisory Bodies Law Registration Form: guidance for individual sole trader Schedule 2 directors

Enforcement and penalties

The JFSC has a graduated set of enforcement tools ranging from directions and public statements to civil financial penalties, and unauthorised activity can be a criminal offence. Codes of Practice breaches are not themselves offences but are grounds for regulatory action.

Civil financial penalties

• Natural persons methodology: For a significant and material contravention of the Money Laundering (Jersey) Order 2008 or a JFSC Code of Practice, civil penalties on a natural person are set within four bands: Band 1 (failure to notify) up to GBP 10,000, Band 2 (uncured contravention) up to GBP 200,000, Band 2A (negligent contravention) up to GBP 300,000, and Band 3 (intentional or reckless contravention) up to GBP 400,000.
• Early settlement discount: Discounts of up to 50% (Stage One), 25% (Stage Two) and 5% (Stage Three) may apply, and a penalised person may appeal to the Royal Court on the ground that the decision was unreasonable.
• Enforcement examples: The indexed public statements record penalties imposed on firms, including GBP 86,803.19 on Garfield Bennett Trust Company Limited and GBP 19,211.73 on Belasko Jersey Limited, each for negligent contraventions of the Trust Company Business Code and AML/CFT Code, reflecting a 50% early-settlement discount.

Regulatory and criminal action

• Code non-compliance: Breach of a Code of Practice is grounds for JFSC action including written directions, public statements, financial penalties or revocation of registration, and the Code is admissible in evidence.
• Directions: The JFSC may issue directions barring individuals from performing functions in a registered person's business without prior consent, as done against the former directors of Allied Trust Company Limited.
• Unauthorised Schedule 2 business: Conducting Schedule 2 business without registering where required is an offence carrying up to 7 years' imprisonment and a fine; public warning notices have been issued against unauthorised and impersonating entities such as Dandoo Express Group Plc and A.F. Nominees Limited.
• Disclosure Law offences: Providing false or misleading information, and non-compliance with notification, annual confirmation or nominated person requirements without reasonable excuse, are criminal offences under the Disclosure Law, and general partners of partnership-type entities can be criminally liable.
• Late filing fees: Failure to complete and return an SRDC request by the deadline is a Code of Practice breach that may trigger a late filing fee under the fees notices.
• Criminal referral: The JFSC may refer possible criminal offences discovered in its functions to the police and/or the Attorney General, with prosecution remaining solely the Attorney General's decision.

Sources: Financial Services (Disclosure and Provision of Information) (Jersey) Law 2020 · Insurance Business Code of Practice · Investment Business Code of Practice · Money Service Business Code of Practice · Civil Financial Penalties on Natural Persons: Methodology for Determining the Amount · Guidelines on interpretation of Article 36 of the Proceeds of Crime (Jersey) Law 1999 · Guidance note: making a referral to the police and/or the Attorney General (2024-04-16) · Updates to our 2024 supervisory risk data collection (2024-09-27) · Dandoo Express Group Plc (the scam entity) (2025-12-04) · Garfield Bennett Trust Company Limited (2025-08-06) · Belasko Jersey Limited (2024-10-11) · A.F. Nominees Limited (the impersonating entity) (2023-11-06) · Allied Trust Company Limited, and Messrs Antony Kurt Bryans (R), Michael John Lezala (R), Pierre Humphrey Stonborough (R), and Mrs Michelle Clark (R) (2015-06-11)