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Financial crime prevention programme
The JFSC is engaged in an extensive programme of work relating to financial crime prevention. This programme of work involves all our divisions and requires us to work in partnership with government and Industry.
We will continue to combat financial crime through a regulatory framework which is recognised internationally as making Jersey unattractive for money launderers and terrorist financers.
While the forthcoming MONEYVAL assessment is focusing minds and driving an island-wide programme in which we play an important part, we believe that our ability to tackle financial crime over a prolonged period is crucial to maintaining Jersey’s international reputation.
Focusing on fighting financial crime
The programme has a number of projects which focus on the following:
conducting an increasing number of risk-based financial crime compliance focused examinations
completing the National Risk Assessment with the Government of Jersey and, where relevant, leading the implementation of any changes
identifying and proposing solutions for gaps in Jersey’s Anti-Money Laundering and Countering the Financing of Terrorism (AML / CFT) regime
building statistical evidence to show Jersey’s effectiveness in fighting financial crime using supervisory risk data
developing our supervisors’ capabilities through structured training and development so we are recognised as an AML / CFT centre of excellence
increasing significantly our engagement with Industry on AML/CFT risks and how to tackle them
We continue to review the AML/CFT regulatory regime and make recommendations to the Government of Jersey. These recommendations help facilitate Jersey’s compliance with the requirements of the 2012 Financial Action Task Force (FATF) Recommendations.
We have already undertaken a lot of work on the current AML/CFT registration exemptions and will now focus on:
reviewing the extent these exemptions are used
assessing whether there are any potential gaps in technical compliance with the FATF recommendations
understanding the impact withdrawing or modifying an exemption may have.
We are asking for assistance from Industry with this project and have engaged Helen Hatton as an external project adviser. Helen will be responsible for organising and chairing meetings with industry consultation groups, to develop pragmatic solutions. These solutions will also inform future discussions with government and therefore any further consultation on proposed legislative or administrative amendments government may decide upon in relation to changes to the law.
Helen has sought multidisciplinary representation for Working Groups from industry bodies, covering legal, accountancy, advisory, compliance, trust company business and funds administration view-points. The tenor of the Working Groups has been open, collaborative and constructive. The first Working Group has completed its review of seven exemptions. The second Working Group is underway with a further 19 exemptions under consideration.