2025 suspicious activity reporting examination feedback
2025 suspicious activity reporting examination feedbackExecutive summary
This thematic examination programme assessed how well supervised persons were complying with their legal and regulatory obligations under the Money Laundering (Jersey) Order 2008 and the code of practice in the AML/CFT/CPF handbook for suspicious activity reporting.
We carried out the examination following a Recommended Action in Jersey’s 2024 MONEYVAL Mutual Evaluation Report, which highlighted the need to improve how supervised persons identify and report suspicious activity to the Financial Intelligence Unit, Jersey (FIU).
Key findings
Overall, the firms examined showed a good level of compliance, with four out of nine receiving no findings. Where deficiencies were found, the findings related to:
- board oversight of timeliness of reporting by the money laundering reporting officer (MLRO)
- policies and procedures not updated to reflect current requirements (most common)
- suspicious activity reports (SAR) register and records (most common)
- role and independence of the MLRO (most common)
- ongoing training of the MLRO
- compliance monitoring of SAR related systems and controls
All examined firms received feedback, and those where findings were identified were required to submit a formal remediation plan to their supervisor, setting out the actions required and timescales for completion.