Section I Global Footprint integrity checking 2021

Guide to integrity checking your Section I risk based supervision data

1 Introduction

We will once again be requesting the provision of specified data through completion of a number of Excel workbooks. Section I of the exercise collects substantially the same data as we have collected for years 2017 to 2020.

This guide is intended to assist Reporting Entities perform a “sense check” on the completed Section I – Global Footprint Excel workbook prior to submitting it to us by highlighting the:

  • mandatory questions (section 2); and
  • relational questions (section 3).

On submission of your Section I Excel workbook you will receive an email confirming that you have successfully submitted your data. If you do not receive an email contact myjfsc@jerseyfsc.org as there may be an issue with your submission.

Note that whilst your submission may be successfully received by us, you may be contacted by a member of the Supervision division to discuss your data if any of the mandatory questions remain unanswered, or the relationship between certain questions has not been maintained.

To limit the number of “failed” submissions, Reporting Entities are advised to consider sections 2 and 3 of this guide before submitting their data.

2 Mandatory questions

The tables below detail the questions which are mandatory and indicate the nature of the data to be reported.

Question number

Data required (summary text)

Data type

A1

Full name of Reporting Entity

Alpha numeric characters

A2 and A3

A2 must be completed by a Reporting Entity registered to carry on one or more of: (a) deposit-taking; (b) trust company business; (c) investment business; (d) fund services business; (e) AIF services business; (f) money services business; (g) general insurance mediation business (class P or Q); and (h) insurance business

X to indicate all that apply

A3 must be completed by a Reporting Entity:

(i)   registered to carry on a Specified Schedule 2 Business such as lawyers, accountants and lending; and

(ii) which is a regulated business carrying on any activity listed with question A3(6)(a) to (n)

Dropdown menu

(Yes ; No)

A17(a)

Total income (as an absolute value e.g. GBP 10,000)

Number

A17(b)

Estimate of income from regulated/Specified Schedule 2 business activity for the same period as reported in A17(a) (as an absolute value e.g. GBP 8,000)

Number

A18

Number of employees (full time equivalent)

Number

A19

Number of employees (full time equivalent) working in compliance and risk

Number

A21

Total number of customers

Number

Question number

Data required (summary text)

Data type

The following are mandatory for Reporting Entities except those that only carry on (i) ‘general’ insurance business or (ii) class P or Q general insurance mediation business

A22

Total number of unique beneficial owners and controllers of customers

Number

B1

Number of SARs handled internally

Number

B2

Number of SARS submitted to a FIU (JFCU or overseas)

Number

B3

Average number of working days to process an internal SAR

Number

B4

Longest number of working days taken to process an internal SAR

Number

B5

Number of ‘no consent’ responses received from an FIU (JFCU or overseas)

Number

B6

Number of requests for information served by an FIU (JFCU or overseas)

Number

B7

Number of production orders received in respect of an AML/CFT matter or TIEA

Number

B8

Number of disciplinary actions taken against employees

Number

B9

Indication of the screening system

X to indicate all that apply

B11

Frequency of screening whole database

Dropdown menu

C1

Number of financial sanctions positive matches

Number

C2

Number of financial sanctions positive matches reported

Number

C4

Value of funds or other assets frozen under a Jersey sanctions regime

Number

3 Relational questions

There are certain questions which have a relationship with each other. For example, depending on the answer given to a particular question another question may become mandatory.

We will test these relationships on receipt of your submission and if there are any discrepancies you may be contacted by a member of the Supervision division with respect to your data.

For your information, the relational questions are explained below:

Question numbers

Relationship

A2 & A3

Participating member column of A3 should only be completed if the Trust Company Business box in A2 is completed.

A3 & A10

If A3 includes a ‘yes’ against ‘Accountants’ then A10 must be completed.

Conversely A10 should not be completed unless A3 ‘Accountants’ has been answered as ‘yes’.

A4 & A2

Only complete A4 if:

  • the Trust Company Business box in A2 is completed AND
  • the Reporting Entity is an affiliation leader.

A5 & A2

Only complete A5 if:

  • the Trust Company Business box in A2 is completed AND
  • the Reporting Entity administers any private trust companies.

A6 & A2

Only complete A6 if:

  • the Fund Services Business box in A2 is completed AND
  • the Reporting Entity is registered to carry on class ZK business.

A7 & A2

Only complete A7 if:

  • the Fund Services Business box in A2 is completed AND
  • the Reporting Entity is providing any service to an unregulated fund.

A8 & A2

Only complete A8 if:

  • any one of the Trust Company Business, Investment Business or Fund Services Business boxes in A2 are completed
    AND
  • the Reporting Entity is providing services to a Supported Fund Operator as (defined in the guidance document).

A9 & A2

Only complete A9 if:

  • any one of the Trust Company Business, Investment Business or Fund Services Business boxes in A2 are completed AND
  • the Reporting Entity is providing services to private funds or a service provider of a private fund.

A11(a) & A11(b)

If the response to A11(a) is ‘yes’ then A11(b) must be completed.

A12(a) & A12(b)

If the response to A12(a) is ‘yes’ then A12(b) must be completed.

A17(a) & A17(b)

Income reported at A17(b) must be less than or equal to that reported at A17(a).

A21 & A22

A22 cannot be ‘0’ unless A21 is also ‘0’.

If A21 and A22 are ‘0’ an explanation of why ‘0’ is the correct response should be provided on the Excel sheet ‘E-Comments’.

B10(a) & B10(b)

For each trigger event indicated in response to B10(a) a response must be provided in B10(b).

C2 & C3

If the response to C2 is any number other than ‘0’ C3 must be completed.

C4 & C5

If the response to C4 is any number other than ‘0’ C5 must be completed.