Industry update

Handbook update on complex structures and criminal background checks

We have updated sections 4.8, 7.8, and 10.6 of the AML/CFT/CPF Handbook to provide clearer, more practical guidance on complex structures and enhanced criminal background checks.

These changes are based on your feedback and aim to make our guidance easier to understand and apply.

From 31 May 2026, our new AML/CFT/CPF handbook will be effective.

Complex structures

In November 2025, we published a follow-on consultation asking for your feedback on proposals to split complex structures guidance in the AML/CFT/CPF handbook into two parts.

Summary of our response

In response to your feedback, we have:

  • kept simple baseline indicators and clarified they are non prescriptive
  • adjusted wording to reflect common Jersey structures
  • confirmed that complexity alone does not trigger high-risk classification or enhanced due diligence (EDD)
  • removed measures from the EDD section that were considered standard customer due diligence

Read the full feedback on follow-on consultation: AML/CFT/CPF Handbook enhancements to complex structures.

Criminal background checks

FAQs

We have published frequently asked questions to help you find clear answers to common questions we receive about enhanced criminal background checks.

See our criminal background checks FAQs.

Guidance

We have also updated guidance in section 10.6 (paragraphs 52 and 53) of the AML/CFT/CPF handbook, based on the feedback you shared with us. This update aims to give more context to help you in practice.

Drop-in sessions

We are hosting two drop‑in sessions to discuss our updated guidance on criminal background checks on:

  • Wednesday 22 April 2026
  • Monday 27 April 2026

Sign up to attend, meet our team and ask any questions you have.

Next steps and resources

Our updated AML/CFT/CPF handbook will come into effect on 31 May 2026.

It will include:

  • the changes originally shared in the draft consolidated handbook from November 2025
  • the additional updates on complex structures and criminal background checks outlined in this industry update

To review all updates, please refer to the draft consolidated handbook, except for sections 4.8, 7.8, and 10.6, which have been revised and can be accessed using the links below:

Contact us

If you have any questions, contact our policy team.