Key Takeaways from FIU Jersey's 2025 Annual Report: Growth, Transformation & Global Reach

• The Financial Intelligence Unit Jersey (FIU) 2025 Annual Report details a year of operational growth amid organisational transformation under the "Firm Foundations" strategy.
• The FIU
• Received 2,160 Suspicious Activity Reports (SARs) — an 18% increase from 2024 — plus over 3,600 other reports.
• Banking remained the dominant sector for SARs (58%),
• Fraud as the leading predicate offence.
• PEP-related reporting continued to decline.
• It disseminated nearly 1,900 intelligence reports (1,121 locally and 780 internationally)
• Handled 2,607 consent requests (76% granted).
• Key achievements included
• The successful relocation to Maritime House,
• Progress on adopting the goAML platform for modernised case management,
• Continued strong international cooperation (sharing with 84 countries, 46% of Egmont Group members), and
• Active typology reporting on emerging risks such as environmental crime, sanctions circumvention, virtual assets, and proliferation financing.
• Challenges included
• Government resource constraints,
• Recruitment controls, and
• External dependencies, which slowed the full implementation of Project Liberty (structured around Location, Legislation, and Technology).
• Despite this, the FIU
• Maintained high operational output,
• Enhanced public-private partnerships via the Jersey Financial Intelligence Network (JFIN), and
• Contributed to Jersey's AML/CFT framework.
• Overall, 2025 positioned the FIU for stronger future capability while demonstrating resilience and international relevance.

Comprehensive Summary

1. Strategic Context and Overview

Director's Message (Ian McDonald, Acting Director):

• The FIU's 2025 objective was establishing "Firm Foundations" focusing on a secure environment, technology, legislation, and professional capability.
• Progress was constrained by external factors (recruitment controls, government dependencies, and post-MONEYVAL follow-up).
• The unit balanced transformation with core operations, increasing SAR intake and intelligence sharing.
• Emphasis on collaboration with domestic/international partners, public-private partnerships (e.g., JFIN, links to UK JMLIT), and addressing evolving threats (state-related, non-traditional, virtual assets).
• Continued engagement with Egmont Group, Council of Europe, and technical assistance to other jurisdictions.

2. Project Liberty – Transformation Programme

Structured around three pillars:

• Location: Major milestone — relocation to dedicated facilities at Maritime House. Provided secure, collaborative spaces for operations, training, and stakeholder engagement. Completed with efficient reuse of government resources.
• Legislation: Proposals advanced but paused due to government decisions on Arm's Length Organisations. FIU will remain within the Department for the Economy; legislative work continues post-2026 election considerations.
• Technology: New reporting portal, workflow, case management, and intelligence database planned. Industry briefing held; staff attended the international user group in Mozambique.
• GoAML TIMELINE:  Significant progress toward an independent goAML platform (UNODC-developed, used by ~75 jurisdictions). In the Technology section of the 2025 Annual Report, it states that while significant progress was made in 2025 on adopting goAML (the new UNODC-developed reporting, case management, and intelligence platform), the full rollout and delivery of this major system will extend into 2026 and beyond.

3. Operational Highlights

• Typology Reporting: Published scenarios on environmental crime, sanction circumvention, virtual asset abuse, and proliferation financing (aligned with National Risk Assessment).
• Partners & Outreach: Active in Egmont Group, European networks, and domestic coordination. Supported capacity building and shared good practices.
• Engagement & Training: Delivered briefings, events, and digital outreach (LinkedIn) to improve reporting quality and threat awareness.
• Case Impact: Intelligence supported investigations, financial disruption, and prevention efforts.

4. Key Statistics (2025)

SARs Received:

• 2,160 SARs (18% ↑ from 2024; avg. 9 per working day).
• 99% under Proceeds of Crime Law.
• Banking: 58% of SARs.
• Significant increase from Virtual Asset Service Providers (VASPs).
• Sectors: Banking and TCSPs are dominant; VASP growth is notable.

Predicate Criminality (top categories):

• Fraud (most common).
• Tax crimes, corruption.
• High "Other – undetermined" (~38%).
• Notable rise in sexual exploitation reports (sector-specific).

Geography:

• Top countries: UK, Jersey, Hong Kong, UAE.
• Increases in Hong Kong and UAE reporting.

Persons & Entities:

• 2,651 natural person connections (2,009 suspects, +27%).
• 73 SARs involved PEPs (downward trend); PEP suspects decreased 27%.
• 1,440 legal person/arrangement connections (+15%); overseas entities prominent.

Assets:

• 67% of SARs (over 1,400) reported assets, mostly Jersey bank accounts.

Other Activity:

• >3,600 other reports (incl. ~2,371 continuation reports).
• >220 requests to local submitters.
• >180 requests to international partners.
• >760 formal requests [RFAs] received (mostly local law enforcement).
• >1,900 disseminations (1,121 local, 780 international) to 84 countries.
• Permission for onward sharing granted >730 times.

Consent Regime:

• 2,607 requests (+18%).
• 76% granted, 14% withheld.
• Increases in "act" and "transact" requests.
• Banking/TCSPs are the largest submitters.

Timeliness:

• FIU: <2 days for consent responses; 7 days for RFAs.
• Submitters: Avg. 6 days for POC notices.

5. Trends (2023–2025)

• Steady SAR growth (78% higher than 2023).
• Banking/TCSP dominance consistent.
• Declining PEP reporting.
• Strong international reach and value of disseminated intelligence.

6. Conclusion & Outlook

• The report portrays 2025 as a transitional yet productive year.
• The FIU advanced its infrastructure and maintained strong operational performance despite constraints.
• Future focus will be on completing goAML implementation, finalising legislative adjustments, and using the new Maritime House base to strengthen intelligence, collaboration, and Jersey's reputation in financial crime prevention.
• The report concludes with a feedback request at go.fiu.je/feedback-product to help improve future products.

SOURCE

https://go.fiu.je/AR2025

https://cdn.prod.website-files.com/6464df252c82010a0d5f893f/6a15606e482a2a51994d0841_FIU%202025%20Annual%20Report.pdf