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Jersey cash business [€15,000 >] are you AML registered with the JFSC? IF NOT, BEWARE!!!


The JFSC has updated Section 14 of the Consolidated AML / CFT Handbook to include additional guidance for high-value dealers. [see links below]

For the avoidance of doubt, a HIGH-VALUE DEALER is:-

  1. Paragraph 4 of Part B of Schedule 2 to the Proceeds of Crime Law defines HIGH-VALUE dealers to comply with the requirements in the Money Laundering Order as being:
    • › Persons who, by way of business, trade in goods and receive, in respect of any
      • Transaction (whether executed in a single operation or in several operations which appear to be linked) of at least €15,000 in total.
      • Payment[s] in cash or a virtual currency of at least €15,000 in total.
    • › Payment refers to payment in or by means of
      • Cash or Virtual currency
    • › "Cash" includes but is not limited to
      • Any of the following, in any currency – notes, coins, travellers' cheques, bearer negotiable instruments
    • › "Virtual currency" means any currency which (whilst not itself being issued by, or legal tender in, any jurisdiction):
  • Digitally represents value
  • Is a unit of account
  • Functions as a medium of exchange
  • Is capable of being digitally exchanged for money in any form.

The JFSC update is designed to assist the retail industry with understanding the above and

  • Identification, assessment and mitigation of risks associated with money laundering, terrorist financing and proliferation financing, and to support the common efforts in combating financial crime.

The main changes are:

  • Additional guidance identifies what a high-value dealer is.
  • Adding case studies highlights various scenarios of money launderers' use of retail businesses.
  • Aligning the guidance wording following the law and international standards.

The updated versions of the Handbook:

A new page dedicated to retail business with guidance about financial crime related to high-value dealers will follow shortly.


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