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Jersey has today [20 April 2021] published its first National Risk Assessment of Terrorist Financing.


This is a vital part of the #FATF standards and an area of significant focus for the #G20 and the international community due to the devastating impact terrorism can have on societies worldwide.

The report concludes that overall, Jersey has adequate systems and controls to mitigate the risks of being used as a conduit for Terrorist Financing and that Jersey is at a medium-low risk of being used as a conduit for TF.

However, International Finance Centers are not immune from TF risk and work on potential common indicators must be enhanced. This is a global challenge, and Jersey proactively takes part in advancing that work with the international community.

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National Risk Assessment of Terrorist Financing

The Bailiwick of Jersey: National Risk Assessment of Terrorist Financing is the first assessment of the threats that Jersey faces of being a conduit for terrorist financing.

The report is part of the requirements of the international standard-setter on financial crime, the Financial Action Task Force (the FATF), and it follows the publication of Jersey’s first National Risk Assessment of Money Laundering in September 2020.

The work to conduct the NRA of Terrorist Financing started in 2017 and the data underpinning the assessment is taken from 2015 to 2019.

The key findings of the Bailiwick of Jersey: National Risk Assessment of Terrorist Financing are:

  1. Jersey is a leading international finance centre with a strong reputation in upholding high standards of financial regulation, in line with international standards, and is consistently looking to take a proactive approach to developing understanding of the financial crime risk that the jurisdiction may face, and that may face other IFCs.
  2. IFCs face particular challenges in detecting terrorist financing due to the absence of common indicators, and they are not immune from terrorist financing risk and can be misused
    • For cross-border movement of terrorist funds including flow-through of terrorism funds;
    • Service provision;
    • Use of complex structures,
    • Abuse of philanthropy; and
    • Use of funds generated domestically by illicit activities.
  3. Therefore, a complex challenge for IFCs around the world is to better understand the risks that they face in respect of terrorist financing.

It is acknowledged that Jersey is at risk of being used as a conduit for terrorist financing, and Jersey actively participates in discussions with other IFCs and international bodies in respect of what can be done to better understand the risks IFCs face.

Jersey conducted its first terrorist financing risk assessment using a methodology produced by the World Bank, enhanced by documents produced by the Financial Action Task Force as well as work conducted between Jersey and other IFCs.

Given the challenge in identifying common indicators of terrorist financing, a large proportion of the work has focussed around financial flows from/to and activities in target jurisdictions. A list of those jurisdictions has been compiled using reliable, independent indices which indicate that:

  1. individuals in, or from, that jurisdiction is at a heightened risk of being involved in financing terrorism;
  2. there is active terrorism or terrorist financing threats
  3. there are strong geographical or other links to countries that have active terrorism or terrorist financing threat; and
  4. there is secondary terrorism or terrorist financing threat (jurisdictions where crimes occur whose proceeds finance terrorism).

This work identified 21 target jurisdictions which were split into two tiers based on risk level.

Various aspects of data were considered and the assessment confirmed that:

  1. there are a number of areas where Jersey has adequate systems and controls in place to mitigate the risks of being used as a conduit for terrorist financing; and
  2. there are areas where additional focus and action is required to both test and strengthen existing controls and further develop understanding.

Overall, the report concludes that there is a medium low risk of Jersey being used as a conduit for terrorist financing.

In order to determine if this rating could be lower, Jersey will need to conduct more work in a number of areas to fully understand the risk it faces from terrorist financing. This will particularly involve data collection (which will be required to support a lower rating) and analysis concerning:

  1. the transfer of funds to target jurisdictions (jurisdictions at heightened risk of being involved in terrorist financing)
  2. the activities of legal entities incorporated in Jersey in target jurisdictions
  3. the activities of not-for-profit organisations (NPOs) and charities from Jersey in target jurisdictions
  4. the compliance with preventative measures of the regulated sector and their associated understanding of terrorist financing risk

Jersey must look to conduct a further risk assessment of NPOs that are at higher risk of being involved in terrorist financing and also conduct a risk assessment of how virtual asset service providers (VASPs) operating in or from within Jersey might be exposed to terrorist financing risk.

Jersey must also look to further develop terrorist financing understanding and capacity across the public and private sector and ensure it develops a more robust skills base to identify, investigate and supervise compliance with terrorist financing requirements.

The UK is a close partner jurisdiction where authorities have significantly greater terrorist financing expertise – Jersey should look for ways to enhance existing arrangements with the UK to assist in identifying any terrorist financing with a link to Jersey and successfully investigating it. Overall, the island should look to utilise the wider skills base in relation to TF that is available in the UK which could be of benefit to Jersey.

The Government of Jersey has undertaken to revise the risk assessment addressing the further work required and initial recommended actions by the end of 2022.

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