Tuesday 25th June 2019
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Comsure operates in:the UK, Jersey, Guernsey

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5th Money Laundering Directive –10th June deadline – did you have your say?

On Monday 10th June deadline the responses to the HMT consultation paper on the implementation of the 5th Money Laundering Directive in the UK needed to be submitted. The 88-page document is daunting. However, an excellent article from Accounting Web gives a good high-level summary of each section of the consultation document, helping accountants to […]

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Jersey Royal Court considers behaviour when dealing with complaints – lessons to be learned – act (and be seen to act) objectively and impartially

SPEED READ The courts considered the arguments from the JFSC concerning integrity of an investment adviser (SWM) when they dealt with two complaints. In complaint No 1 SWM refused to re-open a compliant after being directed to do so by a 3rd party – the court stated it is not unreasonable on the part of […]

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Jersey Royal Court considers record keeping (in particular due diligence) – lessons to be learned

SPEED READ On due diligence the JFSC are specifically clear on the view that centrally important part of proper due diligence is that written records be created to document the steps taken more generally the JFSC are of the view that Keeping records of operational behaviour is essential and the JFSCs views is that 1. […]

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Money Laundering vulnerabilities in London’s Capital Markets?

London is the global leader for raising capital; Its infrastructure, people, breadth of financial services and even the GMT zone itself ensures companies and investors from around the world can intersect. It’s stock exchanges enable companies of all shapes and sizes to float and raise capital, and investors to buy shares. However, with its diverse […]

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Venezuela: A Case Study in Jurisdictional Risk (a Dow jones whitepaper)

Venezuela is not ranked highly on the World Bank’s Doing Business index. It is third-to-last, above only Libya, Eritrea and Somalia. Worse, increased U.S. sanctions on the country have made it an even more complex jurisdiction. However, many large companies still manage to do business in the country, and even more, companies continue to conduct […]

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JERSEY amends AML laws and JFSC rules-codes (the handbook)

Following the Money Laundering (Amendment No.10) (Jersey) Order 2019 coming into effect on 12 June 2019, https://www.jerseylaw.je/laws/enacted/Pages/RO-041-2019.aspx the following amendments should be noted:- Amendment of Money Laundering (Jersey) Order 2008 Article 1 (interpretation) amended Article 3 (meaning of “customer due diligence measures”) amended Article 10A (financial services business carried on outside Jersey) amended Article 11 […]

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BoE, FCA and MAS to collaborate on cybersecurity

On 13 June 2019, Bank of England (BoE), FCA and the Monetary Authority of Singapore (MAS) published a joint press release announcing their intention to work together to strengthen cybersecurity in their financial sectors. The authorities plan to enter into a memorandum of understanding (MoU) to formalise the enhanced collaboration, which will identify effective ways […]

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Leading the Way on Regulation + Sustainable business models

The following is part of a Speech delivered by Karina McTeague, Director of General Insurance and Conduct Specialists Supervision, at the British Insurance Brokers’ Association (BIBA) Conference 2019. Sustainable business models Andrew Bailey, the FCA’s Chief Executive, has previously talked about the UK having had two financial crises: the first, was prudential the second, was […]

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