ASK MAT – "I previously had one NED role and did not register with the JFSC. I’ve now taken on a second role and may add a third shortly. What should I do?"

ASK MAT – "I previously had one NED role and did not register with the JFSC. I’ve now taken on a second role and may add a third shortly. What should I do?"

Thank you for your QUESTION. I understand that, with your existing single NED role, you have not sought JFSC supervision. However, with the addition of a second (and potentially a third) role, you are now asking what may be required. This is a common situation, and I'm happy to outline the requirements and how we can assist.

1. Background on Director Supervision in Jersey
   1. There are broadly three categories relevant here:
      • Non-supervised directors:  Those whose activities do not meet the "as a business for third parties" test (e.g., purely internal roles or very limited non-commercial arrangements). These do not require JFSC registration for AML/CFT/CPF  purposes.
      • Low-risk directors:  Since September 2024, most third-party NED/directorship activities by natural persons are classified as low-risk financial services business under the Low-Risk Order 2024, provided they do not involve certain higher-risk trust company business activities (sometimes referred to as Class G activities).
      • Class G / higher oversight directors: Those whose directorship services include elements that take them outside the low-risk category (e.g., certain structured trust or company administration activities). These may face more stringent AML/CFT/CPF obligations without the low-risk exemptions in place.

1. 2. Concerning (1a, ii & iii) In Jersey, individuals providing director services (including non-executive directors or NEDs) to third parties "as a business"
      • Fall within the scope of Schedule 2 to the Proceeds of Crime (Jersey) Law 1999 and
      • Makes them a "supervised person" under the JFSC's AML/CFT/CPF regime, regardless of whether the companies are Jersey or non-Jersey incorporated, provided the activity is carried on in or from within Jersey.

3. It's possible your single NED appointment meets (1a, ii); however, with your move to two or potentially three roles, it is likely you now meet the "as a business for third parties" test and will need to register.

If my assumption is correct, I expect the two or potentially three roles will meet the Low-Risk Director test (there are a few activities to avoid tripping into Class G / higher oversight directors, e.g. marketing your services as a NED)

1. The Low-Risk Director Test and Supervision
   1. The low-risk classification applies to a natural person acting as a director for third parties, as long as the activity stays within the defined low-risk parameters (i.e., it does not cross into specified excluded trust/company service activities).
   2. As a low-risk director, you become a supervised person but benefit from targeted exemptions; for example, you are not required to maintain full policies and procedures under Articles 7–11A of the Money Laundering (Jersey) Order 2008.
   3. However, core obligations such as customer due diligence (on the companies you direct and their underlying activities), ongoing monitoring, and suspicious activity reporting still apply.
2. JFSC Registration Requirements for Low-Risk Directors
   1. If you are classified as low-risk:
      • You must register with the JFSC as a Schedule 2 business (supervised person) via the myJFSC portal.
      • The process involves completing the relevant Schedule 2 registration form for individuals/sole traders providing director services.
      • There is typically an application/registration fee (exact current amounts are published on the JFSC website under their fees notices; these can change annually).
      • Once registered, you will be subject to ongoing supervisory oversight by the JFSC for AML/CFT/CPF compliance, though at a lighter level than full trust company business.

2. 2. Failure to register when required can result in offences with significant penalties.
3. Maintaining Low-Risk Status
   1. To remain in the low-risk category and benefit from the exemptions:
      • Ensure your directorship activities do not involve the excluded higher-risk elements (Class G-type activities).
      • Conduct and document a simple business risk assessment specific to your director services.
      • Maintain appropriate customer due diligence on the companies you serve and their controllers/activities.
      • Keep records of your compliance steps, carry out ongoing monitoring, and have arrangements in place for suspicious activity reporting and training.
      • Stay within a reasonable number of directorships (less than 6) that you can effectively manage (the JFSC considers capacity and fitness & propriety on an ongoing basis).

2. The JFSC provides guidance notes and FAQs on their website (particularly under Schedule 2 business – Directors) to help with this. I have included much of the reading

How Comsure Can Assist You

1. We specialise in supporting NEDs and other professionals with JFSC Schedule 2 compliance. Our services typically include:
1. A tailored review of your current and proposed directorships to confirm your exact scope and risk classification.
2. Assistance with completing and submitting the JFSC registration application.
3. Preparation of the necessary risk assessment, policies, and procedures (at the lighter low-risk standard).
4. Ongoing support, such as annual reviews, training, suspicious activity reporting advice, and help responding to any JFSC queries.
5. Guidance on maintaining compliance efficiently without unnecessary burden.
2. We can start with a short call or meeting to discuss your specific roles and provide a clear proposal with costs.

Please let me know a convenient time for a quick discussion, or if you have any immediate questions. In the meantime, I recommend reviewing the JFSC's Directors FAQs and the Low-Risk Order guidance on their website (also, I have sourced key reading material)  for further background.

Best regards,

Mathew  

Mathew Beale | Chartered FCSI

Principal & Director
Comsure Compliance Limited
Comsure Limited (Mauritius)
The Comsure Group of Companies mathew@comsuregroup.com www.comsuregroup.com

Co-Founder & CEO
iTrack Ventures Limited
iTrackAML
mathew@iTrackAML.com www.iTrackAML.com

No 1 Bond Street Chambers, St Helier, Jersey, Channel Islands, JE2 3NP
T (Jersey): +44 1534 626841 | Mobile: +44 7797 747490

SOURCES

1. Here is a compiled list of the most relevant and current official sources (as of early 2026) for Jersey JFSC director supervision, low-risk directors, registration requirements, and related guidance.
2. These are the primary documents you should reference when updating or verifying the email content.
3. I have prioritised official JFSC and Jersey Law sources. Where possible, I include direct links and brief notes on what each covers.  

1. Primary Legislation – Low-Risk Director Definition

• Proceeds of Crime (Low-Risk Financial Services Business) (Jersey) Order 2024 (as amended in 2025)
• https://www.jerseylaw.je/laws/current/ro_50_2024https://www.jerseylaw.je/laws/current/ro_50_2024_20250902 (amended version)
• Key content: Defines “low-risk financial services business” for natural persons acting as directors. States that acting as a director is low-risk unless it falls within paragraph 23(2)(b) of Schedule 2 (certain trust company business / Class G activities). Exempts low-risk directors from several full AML/CFT/CPF  obligations (Articles 7–11A of the Money Laundering Order).

2. JFSC Official Guidance on Directors

• Schedule 2 business: Directors FAQs (updated versions available on the site)
• https://www.jerseyfsc.org/industry/sectors/financial-crime-schedule-2-business/schedule-2-business-directors-faqs/
• Key content: Explains the “as a business for third parties” test, indicators of conducting director services as a business (compensation, referrals, advertising, commercial gain), when registration is required, and common scenarios (e.g., one vs multiple NED roles, family companies, non-Jersey companies).
• Guidance for individual sole trader Schedule 2 directors (application form guidance)
• https://www.jerseyfsc.org/media/7320/sbl-application-form-guidance-for-individual-sole-trader-schedule-2-directors.pdf
• https:// www.jerseyfsc.org/media/7032/sbl-application-form-guidance-for-individual-sole-trader-schedule-2-directors.pdf (alternative/older version)
• Key content: Step-by-step help for natural persons / sole traders completing the registration form.
• General Guidance on Natural Persons carrying on the activity of director
• https://www.jerseyfsc.org/industry/guidance-and-policy/natural-persons-carrying-on-activity-of-director/ (Linked from various pages; covers Class G exclusions.)

3. Registration Process and Forms

• Schedule 2 Forms and Guidance page
• https://www.jerseyfsc.org/industry/sectors/schedule-2-forms/
• Key content: Links to the myJFSC portal registration form and guidance documents. Registration is done via the myJFSC portal.
• Guidance to Schedule 2 Supervisory Bodies Law Registration Form Available via the above page or directly linked in FAQs.

4. Fees (Current for 2026)

• 2026 JFSC Fees Notice (full document)
• https://www.jerseyfsc.org/media/kdpn4ow1/2026-fees-notices.pdf
• Key content: Details application/registration fees and annual fees for Schedule 2 businesses, including individual directors / sole traders. Fees are levied under the Supervisory Bodies Law.
• Schedule 2 Other Specified Business Fees Notice (related 2025 version for reference)
• https://www.jerseyfsc.org/media/7946/schedule-2-other-specified-business-fees-2025.pdf

5. AML/CFT/CPF Handbook (applicable with low-risk exemptions)

• Handbook for the prevention and detection of money laundering, terrorist financing and proliferation financing (current version)
• https://jerseyfsc.org/media/f2adgchx/updated-handbook-clean-version.pdf
• Key content: Full obligations for supervised persons.
• Low-risk directors benefit from targeted exemptions but must still meet core requirements (customer due diligence, ongoing monitoring, suspicious activity reporting, training, record-keeping, and a simple risk assessment).

6. Additional Useful JFSC Pages

• Guidance and Policy main section (filter by financial crime or Schedule 2)
• https://www.jerseyfsc.org/registry-guidance-and-policy/https://www.jerseyfsc.org/industry/guidance-and-policy/
• myJFSC Portal (for actual registration)
• https://myprofile.jerseyfsc.org/ (login required)

Supporting / Explanatory Articles (for context only – not official law)

• Comsure Group articles (useful summaries):
• http://www.comsuregroup.com/news/jersey-as-of-10th-sept-2024-low-risk-director-is-defined-in-law-and-exemptions-are-applied/
• http://www.comsuregroup.com/news/the-jfsc-says-low-risk-lenders-do-not-need-a-bra-what-about-low-risk-neds/