Repeat non-compliance prompts reminder to businesses to review examination feedback
There were 46 findings in our 2020 supervisory risk examinations. These spanned: preventing and detecting financial crime, board responsibilities, compliance monitoring plans, outsourcing and the use of technology.
Approximately 40% of the findings highlighted non-compliance or partial non-compliance with the statutory and regulatory requirements set out in the Money Laundering (Jersey) Order 2008 and Handbook for the Prevention and Detection of Money Laundering and Financing of Terrorism for Regulated Financial Services Business. Almost a quarter of the 46 findings related to board and senior management oversight.
Examples include findings concerning customer risk assessments, customer due diligence and ineffective arrangements for monitoring transactions and customer business and risk profiles. In addition, boards or other senior management were not always able to evidence that governance arrangements were adequate to ensure that the business and affairs of the Registered Person were being effectively monitored and controlled.
Overall, the findings from these examinations were similar to the key themes or detailed findings described in feedback papers published in 2019 and 2020 and most recently on 31 March 2021. We encourage regulated businesses to read these papers to identify any areas where they may need to make improvements to their own arrangements.
We have provided all businesses that we examined with direct feedback and, where we identified findings, they are subject to a formal remediation plan.
We would like to thank the selected businesses and their staff for their assistance during the examinations.