DNFBPs

Who is caught

Designated Non-Financial Businesses or Professions (DNFBPs) are one category of 'Schedule 2 business' regulated for anti-money laundering, counter-terrorist-financing and counter-proliferation-financing (AML/CFT/CPF) purposes under Schedule 2 to the Proceeds of Crime (Jersey) Law 1999 and the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008. They sit alongside Financial Institutions (FIs) and Virtual Asset Service Providers (VASPs) within the same Schedule 2 registration regime supervised by the JFSC.

Who is caught

• DNFBP activities: The instruments name accountants, lawyers, estate agents (real estate agents), high value goods dealers, casinos, and trust and company service providers as DNFBP / specified Schedule 2 businesses.
• Related Schedule 2 categories: The same registration framework also captures Financial Institutions and Virtual Asset Service Providers; a person conducting more than one Schedule 2 activity must consider the requirements applying to each.

What brings a person in scope

• Conducted as a business: Under the JFSC guidance on Article 36, an activity must be carried on 'as a business' (indicators include holding out to the public, profit motive, level of compensation, and multiple activities or customers) and, for FI activities, for or on behalf of a customer.
• In or from within Jersey: Separate JFSC guidance treats a person as carrying on Schedule 2 activity in or from within Jersey where it is managed and controlled from Jersey, has a physical presence there, or has employees or agents operating there with a degree of permanence.
• Registration trigger: A person meeting these tests must register with the JFSC as a Schedule 2 business under the Supervisory Bodies Law.

Sources: 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 · Feedback on enhancements to the AML/CFT/CPF Handbook (2025-11-27) · Feedback Paper on Consultation No. 15 2022 - Proceeds of Crime (Supervisory Bodies) fees (2022-12-30) · Feedback on follow on consultation on AML/CFT scope exemptions (2022-12-15) · Response Paper: Consultation on amendments under the Financial Services Commission (Jersey) Law 1998 regarding the civil financial penalties regime (2021-12-03) · Guidance to Schedule 2 Supervisory Bodies Law Registration Form - myJFSC (Revised January 2024) · Notification of change of principal person, money laundering reporting officer or money laundering compliance officer for Schedule 2 business · Notification of Regulated Business - Additional Schedule 2 Business · Mr Kevin Robert Manning (R) (2019-11-20)

Key duties

The core duty is registration as a Schedule 2 business, followed by ongoing AML/CFT/CPF governance, notification, fee and data-return obligations. Several of these carry fixed deadlines.

Registration and notification

• Registration: Persons conducting Schedule 2 activities as a business in or from within Jersey must register with the JFSC and specify all activities they conduct, both at registration and on an ongoing basis.
• Additional Schedule 2 business: Regulated businesses already licensed under other Jersey financial services laws must notify the JFSC when they also carry on Schedule 2 business, using the Article 11(6) notification form.
• Change of key individuals: Registered persons must notify the JFSC of a change of Principal Person, MLCO or MLRO within one month of the appointment taking effect or the person ceasing to act, providing a certified passport copy for new appointees.

AML/CFT governance and records

• Officers and policies: Registration requires identification of an MLRO and MLCO and confirmation of AML/CFT/CPF policies, procedures, training and a business risk assessment (BRA).
• CDD and monitoring: Supervised persons must perform customer due diligence, monitor for suspicious activity, and file and keep records of suspicious activity/transaction reports and financial sanctions matters; sanctions screening applies to all relationships and one-off transactions regardless of risk.
• Handbook compliance: DNFBPs must comply with the consolidated AML/CFT/CPF Handbook, including sector guidance for lawyers and accountants and periodic enhancements with stated effective dates.

Fees and data returns

• Annual fee: The annual registration fee (a base fee plus a per-employee element, subject to a cap that has changed over successive fee notices) is payable in full on or before 31 March each year; fee-calculation information must be supplied by the same date.
• Application and amendment fees: Non-refundable application fees and amendment fees (for name changes or condition variations) are due at the time of application, with a discount available where the application is made via an AMLSP for certain business types.
• Supervisory risk data collection: Registered and supervised persons must complete and return the JFSC's supervisory risk data collection (SRDC) workbooks by the deadline set for each cycle.

Using an AMLSP

A relevant person may appoint an Anti-Money Laundering Services Provider (AMLSP) to help fulfil its obligation to appoint an MLCO and MLRO, but its board retains the non-delegable underlying responsibility as a Schedule 2 business. Eligibility to act as an AMLSP is limited to FSBs/TCBs holding specified Trust Company Business or Fund Services Business classes, per the Article 9A(4) Notice.

Sources: Guidelines on interpretation of Article 36 of the Proceeds of Crime (Jersey) Law 1999 · Updates to our 2024 supervisory risk data collection (2024-09-27) · Updates to our 2025 supervisory risk data collection · JFSC Feedback on Consultation No.12 2023 · Feedback Paper on Consultation Paper No. 5 2023 · Feedback on Consultation No.1 2023: Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008 - Fees for registered persons · Feedback Paper on Consultation No. 15 2022 - Proceeds of Crime (Supervisory Bodies) fees (2022-12-30) · Feedback Paper on Consultation Paper No.12 2022 – Further enhancements to the AML/CFT Handbook · Feedback on Consultation No. 8 2021 – Fees for DNFBP registered persons (Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008) · Feedback on Consultation Paper No. 9 2020: DNFBP Fees under the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008 · Feedback Paper on Consultation Paper No. 3 2020: Revision to the AML/CFT Handbooks · Feedback on Consultation Paper No. 9 2019: Fees for registered persons (DNFBPs) · Guidance to Schedule 2 Supervisory Bodies Law Registration Form - myJFSC (Revised January 2024) · Notification of change of principal person, money laundering reporting officer or money laundering compliance officer for Schedule 2 business · Notification of Regulated Business - Additional Schedule 2 Business · Guide to Anti-Money Laundering Services Provider Application Process · Notice issued under Article 9A(4) of the Money Laundering (Jersey) Order 2008 (2023-04-21)

Exemptions and carve-outs

The instruments describe several carve-outs, most turning on how an activity is carried on or on transitional arrangements.

• 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.
• Non-customer arrangements: Intra-group, employee and sole-owner arrangements are generally excluded from FI scope unless third parties or other activities bring them in.
• Activity outside Jersey: Schedule 2 activity provided solely from outside Jersey is not in scope; the guidance also excludes advice merely received in Jersey, certain overseas persons dealing with a person in Jersey, and activity treated as carried on in Jersey only because a customer gives effect to a contract there.
• Sole trader directors (transitional): Until 30 September 2024, individual sole trader Schedule 2 directors could answer 'No' to certain governance questions (risk assessment, written AML/CFT/CPF policies, training), though CDD, monitoring, reporting and record-keeping duties continued to apply.
• Private trust companies: The TCB private trust company workbook was withdrawn because PTCs now register directly with the JFSC.
• Director exemptions removed: Following the AML/CFT scope realignment, exemptions relating to directors, including the previous de-minimis exemption for a director of up to six companies, no longer exist; providing director services as a business is TCSP business.
• Future risk-based exemptions: Under the recast Schedule 2, future AML/CFT scope exemptions will only be granted by Ministerial Order where a demonstrably low risk of money laundering or terrorist financing is established under FATF Recommendation 1 criteria.

Sources: 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 · Updates to our 2024 supervisory risk data collection (2024-09-27) · Feedback on follow on consultation on AML/CFT scope exemptions (2022-12-15) · Feedback on consultation on AML/CFT scope exemptions (2022-02) · Schedule 2 Supervisory Bodies Law Registration Form: guidance for individual sole trader Schedule 2 directors

Enforcement and penalties

Enforcement runs through criminal offences for unauthorised activity, individual prohibition directions, and fee-related charges, with a civil financial penalties regime being extended to DNFBPs by legislation that the indexed papers describe as confirmed policy rather than enacted law.

Offences

• Unauthorised Schedule 2 business: Conducting Schedule 2 business without registering where required is an offence under the Supervisory Bodies Law (Article 10), carrying up to 7 years' imprisonment and a fine; the JFSC has issued public warning statements naming unauthorised or impersonating entities.
• Notification failures: Failure to comply with the Money Laundering (Jersey) Order notification requirement is an offence under Article 37(4) of the Proceeds of Crime (Jersey) Law 1999, punishable by a fine.

Directions against individuals

• Prohibition directions: The JFSC has issued public statements and directions under Articles 23 and 26 of the Supervisory Bodies Law prohibiting named individuals found not fit and proper from performing any function, employment or position in or for a Schedule 2 business without prior JFSC approval.
• Breach of directions: Breaching such directions is itself an offence under Article 23(15), and any person who knowingly allows a prohibited individual to work in contravention also commits an offence.

Fee and filing charges

• Late payment: Unpaid annual fees attract a 5% late payment charge from the day after the due date, recurring monthly.
• Late filing: Documents not filed by their due date incur a £100 fee for each complete month or part-month outstanding, unless the JFSC has agreed a later date in writing.
• Missing information: Failure to supply fee-calculation information by the deadline incurs a £100 monthly administration fee; late SRDC returns are a Code of Practice breach that may trigger a late filing fee.

Civil penalties (proposed)

Government response and consultation papers confirm the intention to extend the JFSC's civil financial penalties regime to DNFBPs (casinos, real estate agents, accountants, lawyers) and to their directors, key persons and money laundering officers, including for significant and material contraventions of the Money Laundering Order. These papers state these are confirmed policy positions to be enacted through amending legislation, not yet in force at the time of writing.

Sources: Guidelines on interpretation of Article 36 of the Proceeds of Crime (Jersey) Law 1999 · JFSC Feedback on Consultation No.12 2023 · Feedback on Consultation No.1 2023: Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008 - Fees for registered persons · Feedback Paper on Consultation No. 15 2022 - Proceeds of Crime (Supervisory Bodies) fees (2022-12-30) · Feedback on Consultation No. 8 2021 – Fees for DNFBP registered persons (Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008) · Consultation on Jersey Financial Services Commission Civil Penalties Extension (2021-07-07) · Response Paper: Consultation on amendments under the Financial Services Commission (Jersey) Law 1998 regarding the civil financial penalties regime (2021-12-03) · Feedback on Consultation Paper No. 9 2020: DNFBP Fees under the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008 · Notification of change of principal person, money laundering reporting officer or money laundering compliance officer for Schedule 2 business · Stephen Platt & Associates LLP (the impersonating entity) (2026-06-24) · Haman Wong Solicitors LLP (the scam entity) (2021-12-23) · Channel Island Business Brokers (2021-05-24) · Mr Kevin Robert Manning (R) (2019-11-20) · Mr Stephen Andrew Homyard (2016-08-16) · Mr Aldwyn Percival Sully (R) (2012-05-16)