🚨 It's time to spring clean your iSAR, eSAR, and sancSAR policies and training programs! 🌼

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Alert: Your iSAR/eSAR/sancSAR processes are probably out of date after the sanction law changes

The recent amendments to Jersey's Sanctions and Asset-Freezing (Jersey) Law 2019 (via the Sanctions and Asset-Freezing Law (Jersey) Amendment Regulations 2026) came into force on 18 March 2026. These updates primarily broaden the reporting obligations for Relevant Financial Institutions (RFIs) under Article 32, aligning them more closely with UK sanctions legislation.

Key change:

• Previously, reporting was triggered only if the suspicion arose in connection with holding an account, entering dealings/agreements, or being approached by/on behalf of the person.
• Now, RFIs must report as soon as practicable to the Minister for External Relations if, in the course of business, they know or have reasonable cause to suspect that a person is designated (or owned/controlled by one), or has committed/is committing/intends to commit an offence under the law—regardless of any direct prior relationship.

This is a good moment for firms to revisit and strengthen their financial crime reporting compliance frameworks, particularly:

• Internal Suspicious Activity Reporting (iSAR) procedures related to financial crime/sanctions hits/red flags.
• External money laundering/terrorist financing/criminal property  Suspicious Activity Reporting (eAR) processes to the:
• Jersey Financial Intelligence Unit (JFIU) – using POLSAR(for general suspicious activity reports related to money laundering/terrorist financing/criminal property, where applicable.
• External sanctions Suspicious Activity Reporting (sancSAR) processes to the:
• Minister for External Relations (via sanctions@gov.je, using the relevant sanctions compliance reporting form for suspicions under the Sanctions Law and updated on 18 March 2026.
• Staff training on the expanded scope of suspicions, enhanced screening (including for ownership/control), and timely escalation/reporting to avoid breaches.

With the changes effective just days ago, now is an ideal time to review policies, update procedures, and reinforce training to ensure full compliance.

Let's use this as a prompt to double-check your sanctions controls and training updates. Are yours up to date? Please feel free to call Comsure for assistance.

For official details, see:

• The Government of Jersey update: https://www.gov.je/gazette/Pages/SanctionslegislationupdateChangescomingintoforceon18March2026.aspx
• The JFSC announcement: https://www.jerseyfsc.org/news-and-events/sanctions-amendments-now-in-effect

Firms should also check the JFSC sanctions guidance, practical resources, and reporting forms (including suspected breach notifications) at:

• https://www.jerseyfsc.org/industry/international-co-operation/sanctions

#Sanctions #Compliance #JerseyFinance #AML #FinancialCrime

If you want to learn more, how about how Comsure can assist you in dealing with the matters in this post, call Mathew