Concerning findings following JPF thematic review
We have identified a number of areas of concern following the thematic examination we conducted on the role of the Designated Service Provider (DSP) with respect to Jersey Private Funds (JPFs).
Of the six businesses examined, in most cases processes and procedures put in place were not adequate or effective. There were also instances where the JPF annual compliance return was filed confirming that JPFs were compliant with all necessary Jersey AML/CFT requirements when this was not the case.
We also found that in some cases the DSPs didn’t have effective systems and controls in place to be able to give the required declarations.
In total, there were 23 findings identified across the six DSPs. These findings related to:
- Internal systems and controls
- The JPF annual compliance return
- Director services
- Customer due diligence
- Compliance reporting.
The DSPs that we examined acknowledged their deficiencies and in most cases had already started remediation.
As with all examinations, examined businesses were required to produce, and submit to us, a remediation plan designed to address the findings identified. We will take these plans into consideration when deliberating the appropriate next steps.
We have already committed to undertake a review of the JPF Guide, the results of this thematic examination will inform this work.
We would like to thank the selected DSPs and their staff for their assistance during this thematic examination.
On 20 April, we are hosting a webinar where we will discuss these findings in more detail. You can find out more about the session and sign up here.