Jersey remains a top global performer in tackling financial crime

The report Jersey has been preparing itself for over the last few years is here – and it’s good news for the island.

MONEYVAL – the regional body promoting the implementation of effective measures for Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) - has published its Fifth Round Mutual Evaluation Report (MER) for Jersey.

Overall, Jersey has received a very strong report – performing particularly well in the effectiveness of its AML / CFT systems.

The island has been rated as ‘Compliant’ or ‘Largely Compliant’ on 39 of the 40 FATF Recommendations for technical compliance. Jersey’s effectiveness was also strong – with ratings of ‘High’ or ‘Substantial’ against 7 of the 11 Immediate Outcomes.

The report notes there are no fundamental improvements required to Jersey’s AML / CFT framework, but that there are opportunities for further improvement in its practical application to reach a more substantial level of compliance.

Recommendations include improving the quality of its Financial Intelligence Unit’s (FIU’s) products, and in the supervisory approach in respect of targeted financial sanctions (TFS) requirements.

These recommendations for improvement will be actioned in due course. Following the report, a high-level action plan has already been published by the Government of Jersey. You can read the action plan here.

Commenting on the report, Jersey’s Minister for External Relations and Financial Services, Deputy Ian Gorst, said:

"This report demonstrates Jersey’s ongoing commitment to complying with international standards. The work to combat financial crime is not over, and never will be. Like every other jurisdiction, Jersey will have to continue to adapt to meet changing threats. The report endorses our current national strategy and much of the work we are already doing, but we will also address the recommendations made for improving our system."^[1]

You can read MONEYVAL’s executive summary of its Jersey MER here.

MONEYVAL is the official name given to the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism of the Council of Europe. It is one of nine Financial Action Task Force (FATF) Style Regional Bodies (FSRBs) established to disseminate the FATF recommendations worldwide.

The aim of MONEYVAL is to ensure that its members – which include the Crown Dependencies – have effective systems in place to counter money laundering and terrorist financing, and to implement the FATF Recommendations by assessing members’ compliance on a periodic basis.

Preparations for the MONEYVAL assessment included:

• Several online and in-person training sessions for the financial services industry on AML measures and combating CFT.
• A series of "Combating Financial Crime Together" seminars and networking events for the island’s financial services industry. These focused on MONEYVAL and reviewing the significant milestones leading up to the on-site visit.
• Several industry interviews, surveys, case studies, consultations, and reports collecting data.

KPMG were involved in the preparation stage for the Jersey MONEYVAL visit in October 2023, and were selected for interview. This was attended by Paul Eastwood (Tax Partner) and John Sculthorp (Head of Anti Financial Crime Compliance).

Overall, MONEYVAL's evaluation is positive for Jersey businesses. It bolsters Jersey's strong reputation and avoids the challenges faced by jurisdictions that have been unable to demonstrate sufficient progress.

The intense activity leading up to the evaluation and the pace of regulatory change can now be expected to diminish. This is welcome news for businesses that have at times found it challenging to keep up.

It is also clear from MONEYVAL’s observations that continued focus on effectiveness is needed, and there are some areas where limited improvement in technical compliance could be anticipated. The government’s action plan and comments from key figures do not signal a jurisdiction content to rest on its laurels.

Many actions recommended by MONEYVAL are matters for the Jersey government and relevant agencies to consider. In time, they will have knock on impacts for industry in terms of the shape of regulation, supervision and enforcement.

Businesses should continue to anticipate scrutiny of their AML / CFT / CPF measures and respond promptly to refreshed guidance and the broader evolution of regulatory expectations.

Guernsey’s fifth-round evaluation is currently in progress, and the Isle of Man is expecting to receive a sixth-round visit in 2026. We’re hoping both islands will achieve a similar outcome to Jersey.