Feedback published on civil financial penalty methodology consultation
We’ve published a feedback paper following our consultation on proposed amendments to the methodology for determining civil financial penalties for registered persons.
The feedback paper summarises the responses we received and sets out the amendments made to the methodology, which applies from 19 June 2026.
Read the full feedback paper and the updated methodology:
Civil financial penalties on Registered Persons - methodology for determining the amount
Summary of feedback
We received 10 substantive responses from a range of respondents, including registered persons, industry and professional bodies, professional advisers and other stakeholders.
Respondents generally recognised the need to update the methodology to reflect the legislative changes reintroducing monetary caps. Some welcomed the aim of greater clarity and transparency across the methodology, while others raised concerns about whether aspects of the proposed amendments could affect flexibility, proportionality or consistency.
Key themes raised included:
- how the reintroduced monetary caps operate in practice, including their impact on proportionality and deterrence
- concerns that aspects of the proposed amendments could be perceived as more prescriptive or stringent
- the treatment of voluntary reporting, remediation and mitigation
- the role of other aggravating and mitigating factors
- consistency with penalties imposed by the JFSC in other cases
- the application of the guiding principle of having regard to the best economic interests of Jersey
- how settlement discounts are assessed
After considering the feedback, we have made targeted amendments to improve clarity and reinforce that the methodology remains flexible, proportionate and case-specific, rather than a checklist.
Next steps
The revised methodology is now final and published with the feedback paper. It applies from 19 June 2026.
Updates include revisions to reflect the statutory monetary caps, clearer guidance on voluntary reporting and remediation, settlement discounts, and the role of relevant comparable cases. We have also retained the existing +50% Step 5 adjustment range and an updated worked example.
We will keep the methodology under review in light of operational experience, legislative developments and relevant stakeholder feedback.
Outreach and engagement
We’re hosting an industry presentation on Wednesday 24 June from 2:00pm - 3:00pm at the Pomme d’Or Hotel.
The session will provide an overview of the revised methodology and give attendees an opportunity to ask questions.