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Industry update

Consultation feedback published on changes to the reliance and MLCO regime

We have published feedback following our consultation on proposed changes to the reliance and Money Laundering Compliance Officer (MLCO) regimes. This forms part of our wider commitment to support the financial services competitiveness programme, in collaboration with the Government of Jersey.

The changes are designed to reduce the cost and complexity of compliance, making it easier to do business in Jersey while maintaining high standards for preventing financial crime and fulfilling our international obligations.

Read the consultation feedback on proposed changes to the reliance and MLCO regimes.

Summary of changes

MLCO regime

We will:

  • provide additional guidance on when it may not be necessary to appoint an MLCO
  • retain the requirement for firms to maintain appropriate compliance monitoring arrangements, even where an MLCO is not appointed
  • not introduce fixed size thresholds for MLCO appointments, recognising that size alone is not an effective measure across different sectors and business models

Reliance regime

We will:

  • adopt a more flexible, risk-based approach to reliance, with written assurance sufficient for lower-risk arrangements and additional measures required to meet the new ‘adequate steps’ requirement for higher risk relationships
  • make clear that testing is one possible additional measure, but it is not mandatory
  • clarify that up to five working days will generally be considered 'without delay' when obtaining identity evidence through reliance arrangements
  • provide additional guidance on the use of group reliance arrangements

Next steps

The remaining changes to the MLCO regime and the changes to the reliance regime will take effect on 31 October 2026.

We will update our website and supporting materials on 2 November 2026. 

Notifications

We have introduced a one-off notification process for firms that use an AMLSP, reducing administrative burden by allowing AMLSPs to submit notifications in bulk where multiple client firms are affected.

From 2 November 2026 to 31 January 2027, AMLSPs can submit notifications on behalf of their client firms using the AMLSP Schedule 2 MLCO Notification Workbook, available in the data collection area of myJFSC. Relevant AMLSPs will receive an email from myJFSC with further information.

Firms without an AMLSP that choose not to appoint an MLCO should complete the MLCO notification form and submit it to authorisations@jerseyfsc.org. From 1 February 2027, AMLSPs should also use this form for any client firms whose notification was not previously submitted through an AMLSP Schedule 2 MLCO Notification Workbook.

Application forms

The following application forms will be updated to allow applicants to confirm whether they are operating without appointing an MLCO:

  • AMLSP Legal Person Application Form
  • AMLSP Legal Arrangement Application Form
  • Supervisory Bodies Law Application Form

Contact us

For questions about the policy changes, contact policy@jerseyfsc.org.

For questions about myJFSC access contact myJFSC@JerseyFSC.org.