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JERSEY; DSP, AMLSP, PESP ….it all smells like MoMe spirt!!!!


The published JFSC consultation AML/CFT scope exemptions is out. It has been in train for over a year and has had a significant impact on

  1. Private Trust Companies ("PTCs") and
  2. private and institutional investment structures currently enjoy the professional investor-regulated scheme ("PIRS") exemption.
  3. NEDs [less than x6]

The Feedback on the consultation on AML/CFT scope exemptions is here

In the above, we see that Jersey now has a new regulated entity, and goes by the catchy name of - PESP - Previously Exempt Supervised Persons ("PESPs"),

PESPS will need the following:

  1. Separate engagement with an AML Service Provider ("AMLSP"), likely to be its existing TCSP or Fund Administrator
  2. Separately appointed MLRO and MLCO must be Jersey residents and vetted by the JFSC.
  3. Their P&Ps (or adoption of their TCSPs; welcome to the front line of regulatory compliance, clients!)
  4. Their Business Risk Assessment (or a hybrid of their TCSPs BRA remembering to add in the difference in risk and, in particular, client risks)
  5. Potentially, their own AML Compliance Monitoring Programme
  6. AML training for boards of PESPs (client reps on boards will LOVE this)
  7. Maintenance of their own SAR procedures and registers etc.
  8. Regular Compliance Reporting from their AMLSP and documentation of the consideration of AML matters at the PESP level

So what is needed

  1. Just like the MoMe regime that has been in place in Jersey's regulated funds industry for years, TCBs are now being asked to do something similar.
  2. It all results in a greater level of compliance-related work, processes and documentation. The question will be how this is fulfilled. Throw more bodies at it? Put it on the current Compliance team? Employee more albeit Try and find them.
  3. and all the new resources will be busy doing crash courses in how to be an MLRO / MLCO so they can step up and be appointed to PESPs (if they have the appetite).


  1. Alternative solutions are available for your current and future regulatory recordkeeping and reporting requirements.
  2. To assist you, Comsure supports many compliance and AML processes, compliance monitoring reviews, periodic reviews, customer risk assessments, and more.


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