Sunday 17th November 2019
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Comsure operates in:the UK, Jersey, Guernsey

MUSINGS

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Put The Money Laundering Genie Back In The Bottle And Carry On….!!!

In the last 2 days the Times (UK) newspaper has run several articles on Money laundering in the UK – articles include Loopholes allow £400m of criminals’ hidden cash to slip through the net http://thetim.es/1uyCXtR and  London is “money laundering capital” http://thetim.es/1qkNB80 This got me thinking that these headlines offer no surprises (actually my immediate […]

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Has the [bitcoin] CART been put before the [regulatory] HORSE in jersey…..

The JFSC have authorised a Jersey Bitcoin fund and Philip Ozouf is thrilled!!!!….in authorising the fund it is noted Jersey has no specific Anti-Money Laundering legislation or JFSC rules relevant to cryptocurrencies, such as Bitcoin. In fact it has been reported that the JFSC is of the view that an IN-DEPTH ANALYSIS of the risks […]

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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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