Thematic examination for Q2 and Q3 2025 on suspicious activity reporting

On 31 January 2025, we published our selected themes for thematic examinations this year. Suspicious activity reporting (SARs) was one of the three themes selected based on perceived risks and recommended actions from the 2024 MONEYVAL Mutual Evaluation Report. The SARs thematic examinations are scheduled for the second and third quarters of 2025.

We have outlined key information on the areas of focus, timelines and changes to the way we request information from you.

Jersey’s 2024 MONEYVAL Mutual Evaluation Report

The 2024 MONEYVAL Mutual Evaluation Report included a Recommended Action regarding suspicious activity reporting, which stated that we should:

• continue efforts at monitoring and enhancing the effectiveness of internal systems and processes of supervised persons for identifying and reporting of suspicious activity
• ensure that all supervised persons are submitting Suspicious Activity Reports to the Jersey Financial Intelligence Unit (FIU) promptly after a suspicion is formed

Supervised person’s obligations relating to SARs

Supervised persons conducting business in or from within Jersey are required to report knowledge or suspicion of money laundering, terrorist financing and proliferation financing to the FIU in line with their obligations under the Proceeds of Crime (Jersey) Law 1999 and Terrorism (Jersey) Law 2002.

Under the Money Laundering (Jersey) Order 2008, a supervised person must have procedures in place for reporting such knowledge or suspicion of money laundering, the financing of terrorism and proliferation financing activity to the FIU.

In 2019, we conducted onsite thematic examinations to assess the role of the money laundering reporting officer. The scope of these examinations included a review of some obligations on suspicious activity reporting. Most of our findings related to:

• policies and procedures - ensuring the business has effective systems and controls in place to prevent and detect money laundering and the financing of terrorism
• training and awareness - ensuring employees are alert to money laundering and financing of terrorism risks and well-trained in recognising notable transactions or activity which may indicate money laundering or terrorist financing activity

Boards and management teams of all supervised persons were advised to review our findings from the themed examination programme 2019: the role of the money laundering reporting officer and consider their own arrangements to ensure adherence to the regulatory requirements.

In addition, the findings relating to SARs  continue to be prevalent and in some cases are considered serious.

Key areas of focus

The key areas of focus for this thematic examination will be to review and assess whether supervised persons can demonstrate they have met the statutory obligations and regulatory requirements relating to SARs, including those relating to:

• reporting knowledge or suspicion – do staff understand their obligations to report suspicions and are they aware of the difference between their own obligations and that of the supervised person’s?
• procedures for reporting – do supervised persons have adequate and up to date policies and procedures to make it clear to staff what to do in the event a suspicion is formed and do the procedures ensure adequate and accurate records are maintained?
• money laundering reporting officer (MLRO) – does the MLRO have appropriate independence, authority and support to perform their role?
• reporting suspicious activity – does the MLRO make an external SARs as soon as practicable to the FIU where a suspicion is formed and ensure that adequate and accurate records are maintained?
• FIU consent – does the supervised person understand and where appropriate act within the requirements of the consent regime?
• tipping off – does the supervised person and its staff understand and have adequate measures in place to guard against tipping off?
• training – does the supervised person provide adequate training to staff at appropriate frequencies on reporting suspicious activity?
• disclosure to group companies and networks – does the supervised person have adequate systems and controls (including policies and procedures) in place to manage disclosure in line permitted guidelines?

Key dates

Notable dates for this thematic examination are:

If you have any questions in relation to this thematic examination, please contact our Supervision Examination Unit.