Saturday 15th December 2018
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Comsure operates in:the UK, Jersey, Guernsey

MUSINGS

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Data loss & Client money fraud must be a serious regulatory matter – surely!!!!

Whether its client monies or client data – the lack of controls and any subsequent loss in a regulated financial institution causes the island huge reputation risk.  Surely those who cannot control and manage these matters should be held to account particularly where there are regulatory JFSC rules Earlier this year it was reported that […]

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Is there is an AML Elephant in the room?

I note that the 2014 MONEYVAL on-site assessment and subsequent evaluation report on Jersey states there have been a few significant cases where final convictions have been achieved for ML and have consolidated previous case law. It further states there remain some reservations on the effectiveness of ML investigations and prosecutions. I then read in […]

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Channel Island Passporting would build business & cut costs.

I was speaking to someone yesterday who was bemoaning the loss of good (and large) (large not only in capital size but also as an employer) businesses to Guernsey.  This got me thinking…..why not operate a passporting system for those regulated business in the islands – just like they have in Europe but with a […]

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Have CLIENT RISK ASSESSMENT (CRA) ratings become redundant in jersey?

In the JFSC Consultation Paper No. 3 2014 http://bit.ly/SXhSMbit is proposed to extend the categories of customer to any NON-RESIDENT CUSTOMERS (as well as some other categorised categories) to which enhanced CDD measures are required to be applied under Article 15 of the Money Laundering Order. Unless I’m missing something this means for the majority […]

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Potato, potahto, tomato, tomahto OR in this case CRA or RRA?

I have always been careful to pick up on the nuance  between Jersey and Guernsey rules.  In doing so one interesting difference is the term for assessing the risks of clients – in Jersey we say CUSTOMER RISK ASSESSMENTS [CRA] and the Guernsey handbook terms for the same process is RELATIONSHIP RISK ASSESSMENT [RRA].  To […]

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Dazed and confused – the JFSC suggest it is not on their patch and if they are right whose patch is it on?

I have been reading with interest the JEP coverage of the “African gold story” and following yesterdays (2/6/2014) piece that was been written by Michael Morris I felt a musing coming on!!!  The reason for this urge is I’m interested in the quote attributable to John Harris (JFSC) where he says the company was not […]

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JCOA presentation on JFSC visits in 2014

After a straw poll (hands raised!!) of today’s JCOA CPD workshop audience I was interested to see how few JCOA members had not presented the recent JFSC TCB ANNUAL VISIT FINDINGS report to their boards along with a gap analysis against their own systems, controls and procedures.. Today (3rd June 2014) Mathew Beale presented a […]

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Who was to blame at this Jersey regulated business?

On the 14th April 2014 The JFSC has published a public statement on Herald Trust Company Limited [HTC] and affiliated members and in doing so shown that HTC had received funds from a company managed in the United Kingdom that may have been connected to a fraud (proceeds of a crime!!) AND it also identified […]

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