20 January 2026 - JFSC Drop-in Session on complex structures
29/12/2025
Following extensive feedback on its June 2025 AML/CFT/CPF Handbook enhancements consultation, the JFSC has issued a follow-on consultation focused on complex structures.
- https://www.jerseyfsc.org/industry/consultations/follow-on-consultation-amlcftcpf-handbook-enhancements-complex-structures/
- https://www.jerseyfsc.org/media/asybqscq/follow-on-consultation-aml-cft-cpf-handbook-enhancements-complex-structures.pdf
Please drop in to discuss the follow-up consultation focused on complex structures.
- Your input is vital to make sure the Handbook remains practical, proportionate, and aligned with global standards. The JFSC encourage all stakeholders to review the consultation paper and share their views.
Drop in - Where and when
- Town Hall, St Helier, at 12:00 on 20 January 2026
Drop in for an open discussion on the proposals.
- You can register now via Eventbrite to secure your place.
- https://www.eventbrite.co.uk/e/drop-in-session-follow-on-consultation-on-complex-structures-tickets-1978138560685?aff=oddtdtcreator
What’s changing?
The JFSC have revised its approach to ensure a risk-based and proportionate framework.
The updated guidance now distinguishes between:
- Standard Customer Due Diligence (Section 4): guidance for identifying complex structures and applying mitigating measures where the structure is not assessed as high risk
- Enhanced Due Diligence (Section 7): codes and guidance for situations where complexity contributes to a customer being assessed as high risk
Who is affected?
- All supervised persons, including financial institutions, designated non-financial businesses and professions and virtual asset service providers.
Feedback deadline:
- Submit your comments by 12 February 2026 via Smart Survey or through Jersey Finance Limited
Publication of revisions: 26 March 2026
Effective date: 31 May 2026
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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.