Financial crime examinations: Industry feedback
Financial crime examinations: Industry feedbackIssued: 26 June 2020
1 Introduction
The Jersey Financial Services Commission (JFSC) regularly undertakes examinations to assess the extent to which the regulatory framework is being complied with, provides feedback directly to those within scope and also provides a public feedback document which summarises the key findings of those examinations.
The continuing ability of Jersey’s finance industry to attract legitimate customers with funds and assets that are clean and untainted by criminality depends, in large part, upon the Island’s reputation as a sound, well-regulated jurisdiction. Any business that assists in laundering the proceeds of crime, or financing of terrorism, whether: with knowledge or suspicion of the connection to crime; or acting without regard to what it may be facilitating through provision of its products or services, will face the loss of its reputation, risk the loss of its licence or other regulatory sanctions (where regulated and supervised), damage the integrity of Jersey’s finance industry as a whole, and may risk prosecution for criminal offences.
Jersey’s defences against the laundering of criminal funds and terrorist financing rely heavily on the vigilance and co-operation of the finance sector. Specific financial sector legislation (for example, the Money Laundering (Jersey) Order 2008 (Order)) is in place covering a person carrying on a financial services business in or from within Jersey, and a Jersey body corporate or other legal person registered in Jersey carrying on a financial services business anywhere in the world (Relevant Person).
The key to the prevention and detection of money laundering and the financing of terrorism lies in the implementation of, and strict adherence to, effective systems and controls based on international standards. Legislation in conjunction with the Handbook for the Prevention and Detection of Money Laundering and the Financing of Terrorism (Handbook) implements these standards.
The mandate of the Financial Action Task Force (FATF) is to set standards and to promote effective implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and the financing of proliferation, and other related threats to the integrity of the international financial system. Therefore the expectation of the JFSC is that a Relevant Person’s systems and controls to prevent, detect and report financial crime will include measures to mitigate risk associated with money laundering, terrorist financing, financial sanctions, bribery and corruption, proliferation financing and carrying on sensitive business activities.
Given the critical nature of the need for Relevant Persons to implement and comply with effective systems and controls designed to prevent and detect financial crime, the JFSC increased its examination resourcing in 2019, through the introduction of a dedicated team – the Financial Crime Examination Unit (FCEU), and commenced an enhanced program of Financial Crime Examinations in Quarter 4 2019.
In addition to the above, persons registered by the JFSC under Article 9 of the Financial Services (Jersey) Law 1998 or Article 9 of the Banking Business (Jersey) Law 1991 must comply with the principles and detailed requirements in the conduct of its business, as set out in the relevant Codes of Practice. Therefore, where relevant, the Financial Crime Examinations also included reference to these requirements.
2 Scope and Methodology
The first Financial Crime Examinations conducted by the FCEU commenced in Quarter 4 2019 and concluded in Quarter 1 of 2020.
Having reviewed and analysed data held by the JFSC, together with supervisory knowledge of Relevant Persons, a sample of 6 financial services businesses (14 Relevant Persons) was selected to be examined, representing the following licence types: Deposit-taking Business, Investment Business, Fund Services Business and Trust Company Business.
The objective of the Financial Crime Examination in each case was to review and assess, where relevant, the following:
1. Whether the Relevant Person had implemented effective systems and controls to prevent, detect and report financial crime;
2. That the Relevant Person’s systems and controls enabled it to comply with its legal obligations set out in the Order and the Statutory Requirements and Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Codes of Practice detailed in the Handbook;
3. That the Relevant Person’s systems and controls to prevent, detect and report financial crime were being complied with; and
4. The extent to which the risks of money laundering, the financing of terrorism and other financial crimes were understood by the Relevant Person’s Principal Persons; Key Persons and other employees.
The Financial Crime Examinations were conducted over four phases:
Phase One
This was by the way of a formal information request sent to the identified Relevant Persons seeking the provision of information and documents relating to the following:
› Policies and Procedures;
› Business Risk Assessment and Strategy to counter financial crime;
› Records of board and relevant sub-committee meetings together with relevant reports;
› Organisational Structure Charts;
› Job descriptions relating to the Relevant Person’s Principal and Key Persons;
› Training undertaken by the Relevant Person’s Key Persons and other employees;
› Customer documentation;
› Registers relating to, amongst other things, higher risk customers and Suspicious Activity Reports (SARs);
› Reliance on Obliged Persons;
› The use of exemptions from the application of identification measures;
› Monitoring and Testing; and
› Outsourcing of controls and other activity related to the prevention and detection of financial crime.
Phase Two
This comprised of a detailed desk-based review of the information provided by the Relevant Persons under Phase One.
Phase Three
Between three and five days of on-site activity whereby a sample of files were reviewed including customer files, SARs , declined and exited business and departures from the Relevant Person’s policies and procedures. In addition, a number of interviews were held with various employees of the Relevant Person.
In the event that any findings were identified, these were based upon information provided by the Relevant Person and evidence available at the time of the examination. Those findings are detailed in a report that is issued to each Relevant Person.
Phase Four
Findings resulting from each examination are set out in an Examination Report, which is issued to the Relevant Person after a period in which the Relevant Person has the opportunity to review and comment on the factual accuracy of the findings. Findings detailed in the Examination Report are not rated in relation to their severity by the JFSC and are arranged to align with the Section of the Handbook to which they relate. The Key Findings section below is set out in a similar way, for consistency.
Following issuance of the Examination Report, Relevant Persons must agree an action plan with their JFSC Supervisor to address any findings. The JFSC expects that the Board and the Money Laundering Compliance Officer at each Relevant Person will be able to assess the severity of findings contained within the final report, based upon their knowledge of the regulatory framework and the risks faced by their business.
The purpose of this paper is to summarise the key findings and also to provide, where noted, areas of good practice observed by way of example (the areas of good practice observed and referenced herein should not be taken as formal guidance issued by the JFSC as they may not be relevant or appropriate to every Relevant Person).
It is not intended to comprehensively describe all risks that may be associated with non-adherence to the regulatory framework and not all Relevant Persons within scope face the issues described below.
The JFSC takes this opportunity to thank the Relevant Persons for the courtesy and assistance shown during the examination process.
3 Key Findings
3.1 Section 2 of the Handbook – Corporate Governance
3.1.1.1 A Relevant Person must be able to demonstrate: the existence of adequate and effective systems and controls (including policies and procedures); that it has assessed the effectiveness of its systems and controls; and taken prompt action to resolve any deficiencies.
3.1.1.2 In over half of the entities that were examined, minutes of board or other senior management meetings did not reflect that the financial crime matters or risks that were reported by the Money Laundering Compliance Officer (MLCO) or other Key Persons were subject to adequate discussion, challenge and scrutiny.
3.1.1.3 In a smaller number of cases, the lack of a documented record of actions arising from such meetings meant that senior management were unable to demonstrate that they had taken timely action to resolve deficiencies brought to their attention.
3.1.1.4 In two organisations, the terms of reference for senior management committees that were responsible for overseeing the Relevant Person’s key risks did not include financial crime risks within the list of key risks that the committee was responsible for monitoring and managing.
3.1.2 The Business Risk Assessment (BRA) and Strategy
3.1.2.1 A Relevant Person must conduct and record a business risk assessment (BRA). The BRA must be kept up to date. Similarly, the Relevant Person must document a formal strategy to counter money laundering and the financing of terrorism
3.1.2.2 Whilst all of the Relevant Persons within the sample had carried out and documented a BRA, more than half of those were not kept up to date or were not being monitored in accordance with the Relevant Persons’ internal policy.
3.1.2.3 Half of the Relevant Persons within the sample were unable to demonstrate participation in the BRA by the Board or other senior management or that the conclusions of the BRA were subject to adequate challenge and scrutiny.
3.1.2.4 In some instances Senior Management were unable to explain what their input into the BRA process had been and/or describe the key risks detailed in the most recent BRA.
3.1.2.5 In one instance the Relevant Person’s BRA was a group-led initiative, however, it was not clear to what extent risks relating to the Jersey business had been taken into account.
3.1.3 Systems and Controls (including policies and procedures)
3.1.3.1 The Handbook should not be used as a policy and procedure manual but should be used to develop the Relevant Person’s own systems and controls (including policies and procedures) that are adequate, effective and tailored to the Relevant Person’s financial crime risks.
3.1.3.2 A Relevant Person must establish and maintain systems and controls (including policies and procedures) that are designed to prevent and detect money laundering and the financing of terrorism. A Relevant Person must also test that they are effective and are being complied with. A Relevant Person must take timely action to resolve any deficiencies identified.
3.1.3.3 In two organisations, policies and procedures quoted large parts of the Handbook and Order and were not tailored to the Relevant Person’s operations or risk appetite.
3.1.3.4 In a more than half of the organisations examined, it was noted that policies and procedures had not been adequately maintained and/or kept up to date.
3.1.3.5 In two instances, ownership of the responsibility for maintaining policies and procedures was not clear to senior management. In both of those entities, responsibility for the oversight of systems and controls (including policies and procedures) was not documented within the job description of the MLCO.
3.1.3.6 More than half of the Compliance Monitoring Plans (CMP) that were implemented by the Relevant Persons examined to test the effectiveness of systems and controls (including policies and procedures) had not:
› been mapped to the regulatory framework
› been subject to a Compliance Risk assessment and
› taken a risk-based approach to testing
3.1.3.7 Some CMP examined had been established a number of years ago and had not been updated for some time.
3.1.3.8 In two cases, monitoring activity had not taken place within the period of the examination.
3.1.3.9 In another two cases, findings of the CMP were being regularly presented to senior management, but the Relevant Persons concerned were unable to demonstrate that timely action had been taken to resolve those deficiencies.
3.1.4 The Money Laundering Compliance Officer (MLCO), the Money Laundering Reporting Officer (MLRO) and the Deputy MLRO (DMLRO).
3.1.4.1 A Relevant Person must appoint a MLCO; MLRO and if needed a DMLRO. Relevant Persons must ensure that the MLCO and MLRO are appropriately senior, act with independence and are provided with adequate resources to fulfil their responsibilities.
3.1.4.2 The MLCO must regularly report to the Board.
3.1.4.3 MLCOs for two of the Relevant Persons subject to an examination were not able to demonstrate that they provided regular reports to the board or equivalent senior management forum.
3.1.4.4 In one instance, the MLCO provided input into a regional compliance report that was presented at a group risk committee that covered multiple businesses in several jurisdictions. However, it was not possible to identify risks, issues and actions that related to the Jersey regulated businesses covered by the resultant regional report.
3.1.4.5 In five of the Relevant Persons examined, the responsibilities of the MLCO set out in the Order and the Handbook were not adequately reflected or referenced at all in the Key Person’s Job Description.
3.1.4.6 In two cases an individual was acting as DMLRO, but had not been formally appointed and did not have a job description that reflected their DMLRO responsibilities.
3.1.4.7 In one case, the MLCO and wider Compliance department had not been provided with adequate resources to enable them to carry out all of their duties.
3.1.4.8 In two cases, the MLCO was not able to adequately demonstrate that they acted with independence, due to the fact that there was no independent scrutiny over business as usual activities that they were also responsible for. In both instances the MLCO was responsible for: the development of systems and controls (including policies and procedures); carrying out key control activities on behalf of the first line of defence; and monitoring compliance with the Relevant Persons’ policies and procedures.
3.2 Sections 3, 4, 5 & 7 of the Handbook – Customer Due Diligence
3.2.1 Customer Risk Assessment
3.2.1.1 A Relevant Person is required to gather information that enables it to assess the risks of money laundering and the financing of terrorism.
3.2.1.2 In two cases it was observed that information relating to the source of funds for a business relationship was not sufficiently detailed to understand what had generated those funds.
3.2.1.3 In a similar number of cases, a lack of a procedure or guidance note relating to how to establish a customer’s source of funds and wealth meant it was not possible for the Relevant Person to demonstrate that its employees had taken appropriate risk-based steps to determine whether information relating to the customer’s source of wealth (supplied by the customer), was reasonable or whether further validation was required.
3.2.1.4 All Relevant Persons examined routinely carried out on-line searches on potential customers. In several instances, however, there was no documented audit trail that evidenced the outcome of investigations into possible matches or other connections with the customer.
3.2.2 Keeping Information Up to Date
3.2.2.1 A Relevant Person must keep documents, data and information obtained under identification measures up to date, particularly in relation to high risk customers.
3.2.2.2 In over half of the relevant persons examined, a periodic review process was used to achieve this. The reviews in each case were triggered on a calendar basis or by the Relevant Person’s trigger event procedure. Instances were observed where such anniversaries or events had triggered a review, however, documents and information had not been updated, or the review had commenced and had not been completed.
3.2.2.3 In one instance the approach to completing periodic reviews was not risk-based.
3.2.2.4 In one other case, a project had been implemented to clear a backlog of periodic reviews. However, the project did not prioritise the Relevant Person’s higher risk customers.
3.2.3 Politically Exposed Persons
3.2.3.1 Relevant Persons are required to apply enhanced customer due diligence measures (ECDD) in circumstances where the Relevant Person has identified that the customer is a politically exposed person (PEP).
3.2.3.2 In two organisations policies and procedures had yet to be updated to include the definitions of “domestic” and “foreign” PEPs and “prominent persons” following the publication of changes to the Order and Handbook in June 2019.
3.2.3.3 In one case, the Relevant Person’s definition of a PEP in its policies and procedures did not include the consideration of whether an individual qualified as a close associate of a PEP and consequently, whether ECDD then needed to be applied.
3.2.4.1 A Relevant Person must apply ECDD in certain circumstances set out in the Order and in any circumstance where there is a higher risk of money laundering. Such ECDD should include measures that are over and above those applied to standard risk customers.
3.2.4.2 In two instances, Relevant Persons did not take a risk based approach to the application of identification measures and consequently did not apply ECDD measures to their higher risk customers.
3.2.4.3 One Relevant Person had not considered the specific examples where ECDD was required and therefore had not applied ECDD to the small number of its customers that were resident overseas or had not been met face-to-face.
3.2.5.1 The Obliged Persons regime was only used by one Relevant Person that was examined.
3.2.5.2 A Relevant Person must assess the risk of placing reliance on an Obliged Person and make a written record of the reasons why it believes it appropriate to do so.
3.2.5.3 The Relevant Person did carry out a risk assessment of each Obliged Person and could evidence through documented specific meetings that the agreement to utilise each Obliged Person was subject to challenge and scrutiny by the Relevant Person’s board. However, records relating to the risk assessment carried out by the Relevant Person’s Compliance department did not enable it to demonstrate that appropriate enquiries had been made as to the adequacy of the Obliged Person’s systems and controls (including policies and procedures) in relation to the application of identification measures.
3.2.6 Exemptions from CDD Requirements
3.2.6.1 Section 7 of the Handbook describes circumstances where, in limited circumstances where there is little risk of money laundering, exemptions from the need to apply identification measures are available to Relevant Persons.
3.2.6.2 In more than half of the cases, Relevant Persons had yet to fully update their policies and procedures to reflect the changes made to the Order and Handbook in June 2019.
3.2.6.3 In two cases, the Relevant Persons had adopted group-led controls in relation to the application of exemptions from applying CDD measures. These group policies and procedures were not consistent with the AML/CFT Codes of Practice.
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Several Relevant Persons examined had developed template documentation that set out for higher risk business committees: the customer’s business and risk profile; enhanced due diligence measures that had been applied; information that had been gathered; and enhanced scrutiny and other measures that would be or had been applied to mitigate any risks identified. The template was also used to record any actions arising from the committee’s discussions. |
3.3 Section 6 of the Handbook – Ongoing Monitoring
3.3.1.1 Relevant Persons are required to monitor transactions and activity to ensure that transactions are consistent with the Relevant Person’s knowledge of the customer’s business and risk profile.
3.3.1.2 In one instance the Relevant Person was not able to adequately demonstrate that transaction monitoring was being completed in a timely manner, as the monthly compliance monitoring report repeatedly identified that transaction monitoring tests had failed, due to incomplete payment profile information or customer risk profile information.
3.3.1.3 In a further two cases, activity that was considered to be a trigger event by the Relevant Person was not identified by employees and the opportunity to update customer information was not taken.
3.3.2.1 Relevant Persons are required to monitor transactions and activity to ensure that transactions are consistent with the Relevant Person’s knowledge of the customer’s business and risk profile. A Relevant Person is also required to determine whether business relationships or transactions are with a person with a relevant connection to an enhanced risk state (a relevant connection); maintain appropriate and consistent policies and procedures which provide for the examination of such relationships, transactions and activity; and set out its findings in writing.
3.3.2.2 In one instance the Relevant Person was not able to confirm which data sources its customer screening tool used to identify whether or not a customer had a relevant connection.
3.3.2.3 Another Relevant Person had outsourced the initial investigation of screening results to another part of its parent group. The Relevant Person had not undertaken any ongoing due diligence on whether the services provided by another part of its parent group were carried out to the required standard.
3.3.2.4 In a small number of cases Relevant Person’s systems and controls (including policies and procedures) did not include guidance to employees on the steps to take where a relevant connection was identified to sanctions and other measures implemented under law applicable in Jersey.
3.4 Section 8 of the Handbook – Reporting money laundering and terrorist financing activity and Suspicious Activity Reports (SAR)
3.4.1 Policies and Procedure for Reporting
3.4.1.1 Relevant Persons must establish systems and controls (including policies and procedures) to ensure that employees know the identity of the MLRO to whom to make a report and how to make a report as soon as practicable.
3.4.1.2 In half of the Relevant Persons examined, the reporting procedures for employees contained out of date information or provided inaccurate guidance to employees.
3.4.1.3 The majority of the SAR Registers maintained by MLROs did not contain all of the information set out in the AML/CFT Codes of Practice.
3.4.1.4 The records held by MLROs of two Relevant Persons did not enable the MLRO or the Relevant Person to determine whether the internal report made by the employee was raised as soon as practicable after the information that caused the employee to be suspicious came to their attention.
3.4.2.1 A Relevant Person must also maintain policies and procedures that ensure that the MLRO documents all enquiries made, the basis on which an external report is made and keeps the JFCU up to date.
3.4.2.2 In two cases, the MLROs records did not reflect an acknowledgement of the internal SAR from the employee.
3.4.2.3 In a similar number of cases, it was not clear what steps the MLRO had taken to ensure that they were made aware of new information or activity (including the termination of a business relationship), during the ongoing management of a customer who had been the subject of an external SAR.
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Within their evaluation, the MLRO documented a detailed timeline of activity from the date the internal SAR was received until the conclusion, in order to clearly demonstrate any reasons for delays. |
3.5 Section 9 of the Handbook – Screening, awareness and training of employees
3.5.1 Obligation to train relevant employees
3.5.1.1 A Relevant Person must make its employees aware of its policies and procedures to prevent, detect and report money laundering and terrorism financing. In addition, employees need to be aware of the enactments in Jersey relating to money laundering and the financing of terrorism and relevant AML/CFT Codes of Practice.
3.5.1.2 In half of the Relevant Persons examined the training did not contain or contained incomplete information relating to the enactments in Jersey and relevant AML/CFT Codes of Practice.
3.5.1.3 In one example no training had been provided to employees in the 24 months predating the examination.
3.5.1.4 In one case the Relevant Person did not keep records of which employees had been provided with its training in relation to money laundering and the financing of terrorism.
4 Conclusion
Out of a total of 6 financial services businesses (14 Relevant Persons) involved in the examinations, all resulted in findings.
Of the sample of Relevant Persons examined by the FCEU (representing the following licence types: Deposit-taking Business, Investment Business, Funds Services Business and Trust Company Business), there were 43 findings relating to the relevant areas detailed within this paper. These findings were in respect of the Order and the Statutory Requirements and AML/CFT Code(s) of Practice detailed in the Handbook. Whilst all 6 of the financial services businesses examined had implemented a suite of systems and controls (including policies and procedures) to prevent and detect financial crime in line with the obligations of the Order and requirements of the Handbook, there were a considerable number of findings, which meant that those systems and controls were not considered by the JFSC to be adequate and fully effective in many instances.
In general, FCEU examiners noted high levels of awareness of both financial crime related risks and the consequences of non-compliance with policies and procedures amongst employees of Relevant Persons. However, Relevant Persons often had difficulty in demonstrating involvement of senior management (including the Principal Persons) in the development, scrutiny and use of its BRA.
A robust corporate governance framework, of which risk management is an integral part, is important to ensure that a Relevant Person is adequately directed and controlled. The board/senior management have substantial responsibilities for the prevention and detection of money laundering and financing of terrorism, and whilst they are assisted in fulfilling these responsibilities by appointed MLCOs and MLROs, they must ensure adequate oversight of these roles, in order to demonstrate adherence to the regulatory framework. These responsibilities should be clearly documented within the job descriptions of Principal Persons, Key Persons and in the terms of reference of key risk management forums.
The board/senior management of a Relevant Person must be able to demonstrate that it has considered its financial crime risks “in the round” and has subjected its assessment of such risks to adequate challenge and scrutiny. In addition, a robust corporate governance framework will enable the board/senior management to demonstrate that there is appropriate management of its risks, that its systems and controls (including policies and procedures) are effective and that the board/senior management are taking timely action when deficiencies or other matters are brought to their attention.
Adequate policies and procedures are key to the implementation of effective systems and controls surrounding the prevention and detection of money laundering and the financing of terrorism. It is imperative that procedures are tailored to the business, mapped against the Jersey regulatory requirements, adequately maintained, and effectively adhered to. In order to avoid barriers to adherence, it is also important that procedures are clear and easy for Relevant Person’s employees to understand, use and drive a risk based approach to the prevention and detection of money laundering and the financing of terrorism.
It is also important for Relevant Persons to develop an effective, tailored and risk based monitoring plan to ensure that such systems and controls are complied with and remain effective over time. Employees must know:
(i) where to locate a Relevant Person’s procedure for making an internal Suspicious Activity Report
(ii) how to make a report and
(iii) the identity of the MLRO or DMLRO. Such reporting procedures must be clear and easy for employees to follow, whilst enabling the employee, the MLRO/DMLRO and the Relevant Person to all meet their statutory and regulatory obligations.
Another important control over the prevention and detection of money laundering and the financing of terrorism is to have employees who are:
(i) alert to money laundering and financing of terrorism risks and
(ii) well trained in the recognition of notable transactions or activity which may indicate money laundering or financing of terrorism activity. Training is to be tailored to the business and reflect the relevant Jersey regulatory requirements. Testing must then be conducted to monitor whether the training provided is effective, and relevant action taken if necessary.
All Relevant Persons involved in the examination have received direct feedback and where findings have been identified, they are subject to a formal remediation plan having been submitted to and agreed by the JFSC, setting out actions to be taken and timescales to complete them. None of findings detailed in this paper resulted in further action being taken by the JFSC, as the deficiencies were not considered to be sufficiently serious in isolation at each Relevant Person examined. However, that may not have been the case had the deficiencies highlighted serious failings of the Relevant Person’s systems and controls to prevent and detect financial crime, or been deliberate, or occurred over a long period of time without being addressed by senior management.
The above information relating to the findings of Financial Crime Examinations has been published by the JFSC with the aim of enabling Relevant Persons to review examination findings and use the information to assist in the enhancement of their own systems and controls to prevent and detect financial crime. It is expected that the board/senior management of Relevant Persons who were not involved in the examinations also review this paper and consider their own arrangements to ensure strict adherence to the regulatory requirements.
Each Relevant Person in Jersey must recognise the role that it must play in protecting itself, and its employees, from involvement in money laundering and the financing of terrorism, and also in protecting the Island’s reputation of probity.
5 Glossary of Terms
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AML |
Anti-Money Laundering |
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AML/CFT Codes of Practice |
The AML/CFT Codes of Practice contained within the Handbook |
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Board |
Board of Directors the function described in Section 2.1 of the Handbook |
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BRA |
Business Risk Assessment |
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CDD |
Customer due diligence |
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CDD Measures |
Measures set out in Article 3 of the Order |
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CFT |
Countering the Financing of Terrorism |
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CMP |
Compliance Monitoring Programme |
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Customer |
Means a customer of a Relevant Person as defined in the Order and the Handbook. |
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DMLRO |
Deputy Money Laundering Reporting Officer |
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ECDD |
Measures described in the MLO at Article 15 “Enhanced customer due diligence” |
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Guidance |
The Guidance provided to Relevant Persons in the Handbook for the Prevention and Detection of Money Laundering and the Financing of Terrorism. |
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Handbook |
Handbook for the Prevention and Detection of Money Laundering and the Financing of Terrorism for Regulated Financial Services Business |
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JFCU |
The Joint Financial Crimes Unit (Officers of the JFCU are the designated police and customs officers for the purposes of the Money Laundering Order). |
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JFSC |
Jersey Financial Services Commission |
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MLCO |
Money Laundering Compliance Officer |
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Order |
Money Laundering (Jersey) Order 2008 |
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PEP |
Politically Exposed Person as described in Article 1 and 15A of the MLO |
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Person |
Means any natural or legal person (including a body of persons corporate or unincorporated) |
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Relevant Person |
Means a person carrying on financial services business in or from within Jersey as defined under Article 1(1) of the Money Laundering (Jersey) Order 2008 |
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SAR |
Suspicious Activity Report |
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SoF |
Source of Funds |
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SoW |
Source of Wealth |