NPO risk assessment

NPO risk assessment phase two

Help with this risk assessment

We are now starting phase two of our risk data collection exercise by asking selected local non-profit organisations (NPOs), and trust company businesses who administer NPOs, to provide us with additional information.

By analysing this data alongside the data from phase one, we will work the Government of Jersey and other Island agencies to consider how Jersey should supervise NPOs in the future.

The questions have been developed by the national working group, working together with representatives of the NPO sector, the legal sector and a counter-terrorism expert.

It’s important to stress that the questionnaire has been sent to a number of NPOs with very different purposes, objectives, activities and jurisdictional touch points, hence we are anticipating that the answers may vary considerably and in some instances the questions may appear over-egged or unrelated to your NPO.

Our focus is on gaining a better understanding of systems and controls and there may be no requirement for your NPO to have, for example, a risk assessment in place.

Our questions are not intended to diminish, impede or undermine the noble activities of NPOs and should not be perceived as us testing “your knowledge” concerning reporting procedures, the law etc.

Instead, the assessments we are completing will help us gain a better picture of each NPO, so that we can ensure we are supervising them correctly, particularly those that are identified as more vulnerable to misuse for terrorism financing purposes.

To help you complete this assessment, we have mocked up a preview of the form and we have created some guidance for completing it. We strongly recommend that you review this guidance before completing your submission.

You will need to complete and submit this information to us using the same method that you used during the first phase of the assessment.

As before, you will be sent a unique link for accessing the survey. It will need to be completed in one sitting as it cannot be saved and revisited. Additionally, the unique link can only be used once. If you want to keep a copy of the form for your records, you will need to print it using the print option in your browser before submitting it to us.

If you are a trust company business that looks after a NPO, you will need to download and complete an Excel workbook via myJFSC.

Additional support

You can contact us by emailing policy@jerseyfsc.org if you have any questions. It may be that we are unable to respond on the same day, depending on the volume of questions that we may receive, however, we will contact you as soon as we can.

Technical support with submitting your information

If you have any technical difficulties when submitting your information, contact myJFSC@jerseyfsc.org

Why we are doing this risk assessment

The Island is seeking to build a better understanding of Jersey’s non-profit sector and the risk of it being used to finance terrorism. This work follows the Government of Jersey’s National Risk Assessment of terrorist financing which was published in April and highlighted the need for a deeper risk assessment of this sector.

Next steps

The second part of this risk assessment will be conducted between 1 – 30 November 2021, when we will be contacting selected Registered NPOs (which are on the NPO register) and Regulated NPOs (which are administered by trust company businesses).

The data will help determine the approach to supervising NPOs, particularly those that are identified as more vulnerable to misuse for terrorism financing purposes.

Any organisation that does not respond to the questionnaire may be considered higher risk and is likely to be more closely monitored by the regulator.

This is an Island wide project and we are working with the Government of Jersey, local agencies and Industry.

No cause for concern

The word ‘terrorism’ can understandably cause alarm so we want to stress that we are gathering this second round of information in respect of some non-profit organisations so that we can develop an understanding of their systems and controls. This will inform future decision-making.

Unfortunately, there is international evidence of non-profit organisations being misused to finance terrorism. Jersey being a conduit is not an option.

Fighting financial crime, including terrorist financing, are key priorities for us and it is hugely important that we understand and monitor all sectors.

Registered non-profit organisations are reminded that they are required under the Non-Profit Organizations (Jersey) Law 2008 to keep their registration information up-to-date so that we can identify, assess and mitigate any emerging risks.

NPO risk assessment phase one: all local non-profit organisations

What you need to know as a non-profit organisation about our new data requirements:

Help with this risk assessment

We are asking all local non-profit organisations to share with us current information about their purpose, objectives and activities in a drive to fight financial crime and the financing of terrorism.

You will need to complete and submit this information to us online by accessing a unique link in an email we have sent you. If you have not received this email, contact policy@jerseyfsc.org

To help you complete this form, here is some helpful guidance:

Guidance for completing online form for non-profit organisations

Because you can only submit the form once and cannot save and revisit it, here is a preview of the information we are requesting so that you can have the relevant data to hand when completing the form:

Preview of non-profit organisation questionnaire

If you are a trust company business that looks after a non-profit organisation, you will need to download and complete an Excel workbook via myJFSC

Additional support

To provide further information and support with this exercise, we are holding 30-minute one-to-one appointments at our offices which can be booked on a first-come first-served basis. Book your appointment by emailing policy@jerseyfsc.org

In-person appointments: 23 September at 11:00-17:30.

If you are or someone you know is involved with running a non-profit organisation in Jersey and you/they haven’t heard from us, contact policy@jerseyfsc.org

Inactive non-profit organisations

You need to advise us of the date when the non-profit organisation stopped undertaking its activities so that we can remove it from our register.

Notify us by emailing policy@jerseyfsc.org

Incorrect contact details

If you have received our request for information but you are not connected with a non-profit organisation, contact us so we can amend our records and advise us of the new contact for the organisation, if you know who they are: policy@jerseyfsc.org.

Technical support with submitting your information

If you have any technical difficulties when submitting your information, contact myJFSC@jerseyfsc.org

Why we are doing this risk assessment

National Risk Assessment of Terrorist Financing (gov.je)

The first part of this NPO risk assessment will be conducted between 20 September and 5 October 2021 when we will be contacting both Registered NPOs (which are on the NPO register) and Regulated NPOs (which are administered by trust company businesses).

The data will help determine the approach to supervising NPOs, particularly those that are identified as more vulnerable to misuse for terrorism financing purposes.

Any organisation that does not respond to the questionnaire may be considered higher risk and is likely to be more closely monitored by the regulator.

This is an Island wide project and we are working with the Government of Jersey, local agencies and Industry.

No cause for concern

The word ‘terrorism’ can understandably cause alarm so we really want to stress that local non-profit organisations should not be concerned about this exercise. We are simply requesting information so we can develop a better understanding of the sector.

Unfortunately, there is international evidence of non-profit organisations being misused to finance terrorism. Jersey being a conduit is not an option.

Fighting financial crime, including terrorist financing, are key priorities for us so it’s hugely important that we understanding and monitor all sectors.