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Starting this month, the Jersey Financial Services Commission’s (JFSC) Financial Crime Policy (FCP) team will be running a series of Anti-Money Laundering (AML) / Countering the Financing of Terrorism (CFT) ‘refresher’ sessions for industry in the Town Hall.

In contrast to recent presentations, these sessions are not intended to explain any recent amendments nor to introduce any proposed changes to the AML/CFT regime.

Instead, they are designed to act as a reminder or ‘refresher’ in relation to certain aspects of the AML/CFT regime which are the subject of most industry enquiries. The sessions will aim to clarify the current position in these areas and address a number of common queries and misunderstandings.

Sessions will comprise of a 45 minute presentation, followed by a 75 minute ‘drop-in surgery’ where the FCP team will be available to take specific questions.

The sessions will be held as follows:

Wednesday 23 September, 09:00 - Enhanced Due Diligence

To include:
The difference between “high risk” and enhanced due diligence
Application of enhanced measures to current customers
The interplay between simplified and enhanced due diligence

Thursday 29 October, 9:00 - Simplified Due Diligence

To include:
Art 17((A) of the Money Laundering Order (third parties) - significance test
Art 18 of the Money Laundering Order - which elements are ‘switched off’ in each scenario
The interplay between simplified and enhanced due diligence

Wed 18 November, 9:00 - Reliance

To include:
What is / is not reliance (e.g. sections 4.4.5 and 4.5.7 of the AML/CFT Handbooks; Art 3 of the Money Laundering Order)
What cannot be covered by reliance (e.g. nature / purpose, etc.)
Risk assessment - what to cover; Art 16(4) and link to 16(9)(b) of the Money Laundering Order
Assurances - general/specific; include “consent” under 16(3)(a) of the Money Laundering Order
Testing - how / when
Confluence of concessions: Article 16 and 18 of the Money Laundering Order – clarification/conditions

Wednesday 16 December, 9:00 - Beneficial Ownership

To include:
The ‘three tier’ test with examples.
‘Proving a negative

Due to the high demand of the above talks, it is necessary for attendees to register in order to reserve your place. Slides will be published on the JFSC website 24 hours ahead of each presentation. CPD certificates will not be provided.

- Ends -

For further enquiries, please email

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