Comsure's Fractional Compliance Support for Jersey Firms – Unlocking Efficiency

In the fast-paced world of financial services, Jersey firms face mounting regulatory pressures while striving to maintain operational agility and cost-effectiveness.

Since its founding in 2005, Comsure Compliance Limited has deeply understood these challenges. For over 20 years, we have pioneered and delivered innovative fractional compliance support services, tailored specifically for Jersey-based businesses—including trust companies, fund service providers, investment firms, and money service businesses.

Our flexible fractional model provides expert compliance assistance on a part-time or project basis, delivering high-quality, specialised expertise without the overhead of a full-time hire.

This approach has proven effective and increasingly common in Jersey's regulated environment. Throughout these 20+ years, two core principles have remained unchanged and essential:

• Ultimate responsibility and accountability for compliance (the function) always remain with the regulated and/or supervised entity.
• Fractional compliance support enhances and supports the compliance function through targeted tasks, monitoring, projects, and advisory assistance, never replacing the firm's core oversight.

What is Fractional Compliance Support?

• Fractional compliance support is a flexible outsourcing solution that gives firms access to seasoned compliance professionals at a fraction of the time and cost of an in-house team.
• At Comsure, this means engaging our Jersey-based experts to handle:
• Strategic oversight
• Day-to-day compliance monitoring
• Specialised projects (e.g., regulatory audits, risk assessments, policy development)
• Targeted assistance during complex periods, such as navigating AML/CFT requirements or preparing for JFSC inspections
• Our services scale with your needs, allowing you to stay compliant while focusing on growth.
• This approach reduces costs,
• Introduces fresh industry perspectives,
• Mitigates risks, and
• Strengthens your compliance framework.

Why would you choose Comsure as Your Strategic Partner?

• Cost Savings:
• Top-tier expertise without full-time salaries, benefits, or training costs.
• Scalability:
• Increase support during peaks (e.g., regulatory changes, audits) and scale back as needed.
• Jersey-Specific Knowledge:
• Our team is deeply embedded in the local environment, aligning solutions with JFSC, JFIU, and JCOA expectations.
• Proven Track Record:
• We have helped numerous Jersey firms streamline compliance, reduce risks, and support sustainable growth.

Navigating Jersey's Outsourcing Rules (Fact-Checked as of March 2026)

Jersey's frameworks distinguish between formal AML/CFT outsourcing and broader compliance activities:

1. AMLSPs (Anti-Money Laundering Service Providers):
• The only formally defined mechanism for outsourcing MLCO/MLRO FUNCTIONS (and related AML/CFT/CPF obligations) for Schedule 2 entities (under the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008) is through the appointment of an Anti-Money Laundering Service Provider (AMLSP), as permitted per Article 9A of the Money Laundering (Jersey) Order 2008 and detailed in Section 18 of the JFSC AML/CFT/CPF Handbook.
• Comsure cannot offer AMLSP services, but if this is your chosen route, it can support any introductions and or beauty parades
• Once you have appointed an AMLSP, Comsure can offer its Fractional compliance support to either the AMLSP or you, the AMLSP Direct Customer, who has to oversee the AMLSP
2. Compliance Officer (CO) Function:
• For JFSC-registered persons, the CO role is a core in-house FUNCTION under the sector-specific Codes of Practice.
• Unlike AMLSP for MLCO/MLRO, there is no formal outsourcing model for the function
• Fractional support can assist with implementation, monitoring, and related tasks, but ultimate accountability remains with the firm and its appointed CO.
3. Broader Compliance Outsourcing:
• Widely permitted under the JFSC Outsourcing Policy (effective 1 January 2024), including many COMPLIANCE ACTIVITIES below core functions, provided:
1. Arrangements meet policy criteria.
2. Materiality thresholds are considered (e.g., provider failure could impact regulated activities).
3. The firm retains oversight, accountability, and robust risk management.
4. Tipping-Off Risks:
• When sharing sensitive information (e.g., around SARs or investigations), firms must avoid tipping-off offences under the Proceeds of Crime Law and Terrorism Law.
• The Proceeds of Crime and Terrorism (Tipping Off – Exceptions) (Jersey) Regulations 2014 offer protected disclosure exemptions for good-faith sharing to prevent/detect ML/TF.
• For non-AMLSP providers like fractional support, risks are mitigated through limited disclosures, secure channels, confidentiality protocols, and staff training.

Key Reminder:

• Regardless of the model, ultimate responsibility and accountability for compliance always remain with the regulated and/or supervised entity.
• By clarifying these boundaries, we empower Jersey firms to outsource confidently and compliantly.

Would you be ready to Elevate Your Compliance Game?

• Whether you're a startup or an established firm, our fractional model integrates seamlessly. We can advise on whether an AMLSP appointment or broader outsourcing under the JFSC Policy suits your needs.
• Don't let regulatory complexities hold you back. Contact Comsure Compliance Limited today for a free consultation.
• Visit our website or email info@comsuregroup.com.
• Let's build a compliant, resilient future together.