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JERSEY issues another high-risk country list – countries suspected of facilitating terrorist financing.


In September 2023, and as part of the Government of Jersey's programme of combatting financial crime, guidance has been produced on specific countries that may present a higher risk of facilitating terrorist financing (TF)[see country list below]

  1. The publication of this list is in line with the recommendations of the overall National Risk Strategy, the rolling programme of National Risk Assessments, and other measures, such as the Jersey Finance series of seminars that focus on specific countries, including those with a recognised higher risk profile.
  2. The new list is in addition to the JFSC Appendix D1 + Appendix D2
    • The list of countries which FATF considers require the highest level of countermeasures or enhanced due diligence (Appendix D1), and

    • More than 140 countries which have a degree of risk in specific sectors, according to a range of international sources (Appendix D2)


  1. This guidance sets out the methodology employed to create the list of higher-risk TF countries and the results of applying the method.
  2. The list identifies specific countries where more excellent care should be taken when forming business relationships or undertaking one-off transactions with persons that have, or are associated with, persons that have a connection to them. The risks associated with each are very different, as will be the approach to addressing those risks. The measures that need to be deployed depend on which area of risk is being managed.
  3. This list represents the output of the recent work focussing on the national threat as part of the TF risk assessment work. It is published in line with paragraph 7.5.8 of the Update on Terrorist Financing National Risk Assessment, published in May 2023.
    1. and finance/Terrorist Financing National Risk Assessment update 2023.pdf
  4. To maintain this list as a helpful advisory tool, it will be updated regularly. However, there may also be a need to update it ad hoc due to specific events.


  1. Terrorist financing can affect any country. Jersey is no exception. Terrorists need money to finance their operations, and to achieve this, they attempt to abuse financial services and the regulated sectors' products and services, delivery channels, etc.
  2. The FATF Terrorist Financing Risk Assessment Guidance refers to adhering to the Monaco (MONEYVAL) guidance.
  3. It seeks to understand better and apply the different challenges that IFCs, generally with a low domestic terrorism risk, may face.
  4. Against this background, a TF operational working group utilised nine open-source indices and several data sets to determine the final list of countries.
  5. The sources included the Basel AML Index, Jersey Terrorist Financing Cross Border Threat Assessment 2023, the FATF mutual evaluation reports list, and jurisdictions under increased monitoring.
  6. The data sets included.
    • The Egmont Group,
    • As well as several local and UK sources (including the Financial Intelligence Unit's SARs data and that from other Island agencies).
  7. This has resulted in a repeatable methodology that produces a relevant and publishable list of higher-risk terrorist financing countries focusing on the threat related to Jersey as an IFC.



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