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2024 feedback from the 2023 JFSC examination of reliance on obliged persons


During the first quarter of 2023, the JFSC assessed how supervised persons had complied with their obligations relating to reliance on obliged person.

This 2024 feedback paper aims to publish an anonymised summary of the key findings the JFSC identified during the thematic examination and set out relevant good practices for the benefit of all supervised persons.


In strictly limited cases, supervised persons are permitted to rely on measures applied by a third party to meet some of their customer due diligence (CDD) and enhanced CDD measures obligations.

Reliance on third-party measures must always be subject to six conditions in Article 16 of the Money Laundering (Jersey) Order 2008. Where the requirements of Article 16 are not met, supervised persons’ CDD measures may be ineffective, potentially exposing them to a heightened risk of financial crime.

In addition to the requirements in Article 16, the Handbook includes further requirements relating to reliance in the form of AML/CFT/CPF Codes of Practice.


A detailed overview of the examination findings is set out in section 6 OF THE REPORT READ HERE

Supervised persons should consider the findings in this report and, where relevant, implement changes to align with good practice.


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