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99% of SARs are given consent.


A colleague of Comsure attended the JFSC, JERSEYGOV & JFIU hosted DNFB fighting financial crime event on 13th June 2023. The full slide deck is here.

What our colleague reported is as follows:-

Although I can’t remember exactly what was said and it was probably a bit of a throw-away comment, but I think it was Jonathan Groom around slide 47 [full deck] talked about SARS and consent.

What I took away from what was said was.

  • That about 99% of SARs are given consent because they appreciate the seriousness and effect of no consent amounting to an informal freeze.

At first blush this number seems ridiculously high and encouragement for defensive reporting 99% however on further investigation seems consistent with what was said in:-

  • A Jersey judgement - Prospective Applicant v the Chief Officer [See paras 37 of Prospective Applicant – also extracted below]


  • Advocate Redgrave’s article. 13/01/2022 Indefinite informal asset freezes – the beginning of the end? – see extract below.


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