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Jersey AML/CFT/CPF and other supervisory risk data collection – what to expect.


Jersey supervised person were expecting the JFSC 2023 annual AML/CFT/CPF and other supervisory risk data collection request on the February 1 2024 although Comsure has been told for many it has not arrived at the time of writing this update [14:00 - 2 Feb 2024]!

When it does get to you, you must work to a submission deadline of 31 May 2024.

For this year there will be some additional questions to address and for Trust company firms the 2022 data collection for Legal person & arrangements (3 separate workbooks) will be repeated

The additional data questions that have added to previous years is summarised below and found here in the JFSC consultation feedback.

In the consultation there is a list of the questions to stay in to be taken out or  delayed – these are as follows:-

  • 29 questions to be included in this round [SEE the x29 BELOW].



  1. Number of iSAR & eSAR re ML, TF & PF.
  2. Frequency of employee competence & probity checks.
  3. Number of domestic & foreign PEPs declassified.
  4. Number of eSARs submitted to overseas FIUs.


  1. How many customers sent money to this jurisdiction in [year]?
  2. How many customers received money from this jurisdiction4 in [Year]?


  1. How often is screening tool list amended/updated.
  2. Any deficiencies found in screening tool.
  3. What lists are used for screening.
  4. How often is screening tool amended/updated.
  5. What logic is used (fuzzy/exact).
  6. How/when effectiveness of matching criteria last tested.
  7. Which customer types are screened.- H/M[S]/L
  8. Whether list maintained re potential involvement in proliferation.


  1. Number of breaches open over 90 days.


  1. Number of PII notifications made.
  2. Number PII claims paid.
  3. Value of PII claims
  4. Number of open litigation claims.
  5. Number & value of litigation claims paid out.


  1. Number of customer complaints.
  2. Average time to resolve a complaint.
  3. Number & value of ex-gratia payments paid.

Conflicts of interest

  1. Number of conflicts recorded.[LIMITED TO:- friends/family, financial affairs, business affairs, business dealing, employment, associates and affiliates]

Information security

  1. Number of info security incidents where customer info lost and reported to JOIC.
  2. Number of breaches reported to JOIC.
  3. When was your last cyber test?

Vulnerable customers

  1. Number categorised as vulnerable (if applicable).


  1. Names of Governors/Controllers.

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